<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>Income tax reassessment notices and agent assessments: Section 148 time limits and Section 163(2) notice failure voided assessments (2)</title>
    <link>https://www.taxtmi.com/highlights?id=95173</link>
    <description>Reassessment notices under Section 148 for AYs 2002-03 and 2005-06 were held time-barred as they were issued beyond two years from the end of the relevant assessment years; accordingly, the Revenue&#039;s challenge failed on limitation. For AYs 2006-07 and 2007-08, treating the assessee as a representative assessee/agent without issuing notice and passing an order under Section 163(2) was held to be non-compliance with a mandatory statutory condition; the breach could not be cured by relying on the assessee&#039;s conduct, rendering the assessments invalid and sustaining the Tribunal&#039;s view against the Revenue. - HC</description>
    <language>en-us</language>
    <pubDate>Thu, 18 Dec 2025 08:02:00 +0530</pubDate>
    <lastBuildDate>Thu, 18 Dec 2025 08:02:01 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=872425" rel="self" type="application/rss+xml"/>
    <item>
      <title>Income tax reassessment notices and agent assessments: Section 148 time limits and Section 163(2) notice failure voided assessments (2)</title>
      <link>https://www.taxtmi.com/highlights?id=95173</link>
      <description>Reassessment notices under Section 148 for AYs 2002-03 and 2005-06 were held time-barred as they were issued beyond two years from the end of the relevant assessment years; accordingly, the Revenue&#039;s challenge failed on limitation. For AYs 2006-07 and 2007-08, treating the assessee as a representative assessee/agent without issuing notice and passing an order under Section 163(2) was held to be non-compliance with a mandatory statutory condition; the breach could not be cured by relying on the assessee&#039;s conduct, rendering the assessments invalid and sustaining the Tribunal&#039;s view against the Revenue. - HC</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Thu, 18 Dec 2025 08:02:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=95173</guid>
    </item>
  </channel>
</rss>