2025 (2) TMI 985

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..... rs for the relevant AY 2016-17, thus, expired on 31.03.2022. The impugned notice has been issued thereafter, and the same is, thus, barred by limitation.
HON'BLE MR. JUSTICE VIBHU BAKHRU AND HON'BLE MS. JUSTICE SWARANA KANTA SHARMA For the Appellant : Ms Ananya Kapoor, Advocate For the Respondent : Mr Siddharth Sinha, SSC with Ms Dacchita Shahi, Advocate ORDER 1. The petitioner has .....

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..... attention of this Court to the following passage from the said judgment: "46. The ingredients of the proviso could be broken down for analysis as follows: (i) no notice under Section 148 of the new regime can be issued at any time for an assessment year beginning on or before 1 April 2021; (ii) if it is barred at the time when the notice is sought to be issued because of the "time limits specif .....

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..... he new regime applies prospectively. For example, for the assessment year 2012-2013, the ten year period would have expired on 31 March 2023, while the six year period expired on 31 March 2019. Without the proviso to Section 149(1)(b) of the new regime, the Revenue could have had the power to reopen assessments for the year 2012-2013 if the escaped assessment amounted to Rupees fifty lakhs or more .....

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