2025 (4) TMI 330 - HC - Income Tax

Validity of reassessment proceedings beyond period of limitation - HELD THAT - In the present case the period of six years from the end of the relevant AY 2014-15 expired on 31.03.2021. The impugned notice has been issued thereafter and the same is thus barred by limitation.

Summary

The Delhi High Court, presided over by Hon'ble Mr. Justice Vibhu Bakhru and Hon'ble Ms. Justice Swarana Kanta Sharma, addressed a petition challenging a notice issued under Section 148 of the Income Tax Act, 1961, for the assessment year 2014-15. The petitioner argued that the notice was barred by limitation, citing the Supreme Court decision in *Union of India & Others v. Rajeev Bansal*, which clarified that notices under Section 148 could not be issued for assessment years prior to 2021-2022 if the six-year limitation period had expired. In this case, the six-year period for AY 2014-15 ended on 31.03.2021, rendering the notice issued thereafter time-barred. The court agreed with this reasoning, setting aside the impugned notice and allowing the petition.