https://www.taxtmi.com/caselaws?id=462865 The Delhi HC held that a reassessment notice issued beyond the limitation period under Section 149(1) of the Income Tax Act was invalid. The Revenue argued the notice was valid under Section 150's non-obstante clause, claiming it was based on findings from the SC decision in Abhisar Buildwell case, which permitted reassessment in search-related cases under Sections 147/148 even when connected to Section 132 searches. However, the HC rejected this contention, following its earlier decision in ARN Infrastructures India Ltd., where a similar argument was dismissed. The court ruled that the Abhisar Buildwell decision did not constitute a finding or direction justifying notices beyond the statutory limitation period under Section 149. The petitioner's notice was therefore held to be time-barred and invalid. en-us Tue, 29 Apr 2025 00:00:00 +0530 Mon, 21 Jul 2025 19:11:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462865 The Delhi HC held that a reassessment notice issued beyond the limitation period under Section 149(1) of the Income Tax Act was invalid. The Revenue argued the notice was valid under Section 150's non-obstante clause, claiming it was based on findings from the SC decision in Abhisar Buildwell case, which permitted reassessment in search-related cases under Sections 147/148 even when connected to Section 132 searches. However, the HC rejected this contention, following its earlier decision in ARN Infrastructures India Ltd., where a similar argument was dismissed. The court ruled that the Abhisar Buildwell decision did not constitute a finding or direction justifying notices beyond the statutory limitation period under Section 149. The petitioner's notice was therefore held to be time-barred and invalid. Case-Laws Income Tax Tue, 29 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462865