2023 (6) TMI 827 - SCH - Income Tax

Reopening of assessment u/s 147 - Time limit for notice - Scope of new provision section 148A - mandatory procedure of Section 148A followed or not? - as per HC 2022 (9) TMI 883 - DELHI HIGH COURT since the time period for issuance of reassessment notice for assessment year 2013-14 stood extended until 30th June, 2021 and the income alleged to have escaped assessment is beyond Rs.50 lakhs, the first proviso of Section 149 (as amended by the Finance Act, 2021) is not attracted in the facts of this case and even without the benefit of Instruction No.01/2022 the impugned notice is within limitation- HELD THAT - Having gone through the impugned judgment and order passed by the High Court, no interference of this Court is called for. SLP dismissed.

Summary

The Supreme Court dismissed the Special Leave Petition after hearing the petitioner's counsel, Mr. Percy Pardiwala. The delay was condoned, and no interference by the Court was deemed necessary.