https://www.taxtmi.com/caselaws?id=462866 Delhi HC held that reassessment notice issued beyond the limitation period under Section 149(1) was invalid. Revenue argued the notice was valid under Section 150's non-obstante clause, claiming it was based on findings in Abhisar Buildwell case where SC held assessing officers could exercise powers under Sections 147/148 even in search cases under Section 132. However, HC rejected this contention, following its earlier decision in ARN Infrastructures India Ltd., which had dismissed similar arguments. The court ruled that Revenue's interpretation of the Abhisar Buildwell decision as constituting a finding or direction for issuing notices beyond the statutory limitation period was erroneous. The reassessment notice was therefore held to be time-barred and invalid. en-us Thu, 01 May 2025 00:00:00 +0530 Mon, 21 Jul 2025 19:11:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462866 Delhi HC held that reassessment notice issued beyond the limitation period under Section 149(1) was invalid. Revenue argued the notice was valid under Section 150's non-obstante clause, claiming it was based on findings in Abhisar Buildwell case where SC held assessing officers could exercise powers under Sections 147/148 even in search cases under Section 132. However, HC rejected this contention, following its earlier decision in ARN Infrastructures India Ltd., which had dismissed similar arguments. The court ruled that Revenue's interpretation of the Abhisar Buildwell decision as constituting a finding or direction for issuing notices beyond the statutory limitation period was erroneous. The reassessment notice was therefore held to be time-barred and invalid. Case-Laws Income Tax Thu, 01 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462866