High Court Voids Reassessment Notices; Finance Act 2021 Amendments Enforce Strict Time Limits u/s 149.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The High Court quashed the impugned reassessment notices issued u/s 148, holding that the reassessment action was barred by limitation u/s 149(1) read with the First Proviso introduced by the Finance Act, 2021. The Court observed that the Supreme Court's decision in Abhisar Buildwell did not confer a carte blanche to the Revenue to initiate reassessment proceedings overriding the statutory time limits. The observations in Abhisar Buildwell merely clarified that annulment of search assessments would not deprive the Revenue of its power to reassess, subject to fulfilling the conditions u/ss 147 and 148. However, the Revenue failed to initiate reassessment within the prescribed time limits u/s 149(1)(b) or Sections 153A/153C, as applicable pri.........