2024 (7) TMI 581 - AT - Income Tax

Validity of reassessment proceedings as time barred - scope of substituted provisions of the Finance Act, 2021 - amendment by the Finance Act 2021, which introduced the new amended provisions i.e., Sections 147 to 151 with effect from 1st April, 2021 - HELD THAT - As decided in Bhagirathi Barik 2024 (4) TMI 1143 - ORISSA HIGH COURT as also the decision in the case of Nutan Bhusan Jena 2022 (5) TMI 1467 - ORISSA HIGH COURT wherein, the Hon ble Jurisdictional High Court of Orissa had following the decision of Hon ble Supreme Court in the case of Union of India vs Ashish Agarwal 2022 (5) TMI 240 - SUPREME COURT as quashed the notice issued u/s. 148 of the Act and consequential proceedings and orders holding the same as being time barred.

Summary

The appeal was filed by the assessee against the order of the ld CIT(A), NFAC, Delhi dated 13.2.2024 for the assessment year 2013-14. The notice u/s 148 was found to be time-barred based on previous court decisions, leading to the quashing of the notice and all consequent proceedings and orders. The appeal of the assessee was allowed by the Appellate Tribunal ITAT CUTTACK.