The Delhi High Court examined the validity of a reassessment ...

Validity of reassessment u/s 148 challenged - AY 2013-14 beyond block period - Notice quashed.

Case Laws Income Tax

June 3, 2024

The Delhi High Court examined the validity of a reassessment action u/s 148, focusing on the time limit for notice u/s 149 and computation of the "relevant assessment year." It was held that AY 2013-14 fell beyond the ten-year block period. The court emphasized the need to consider the statutory scheme for search assessments pre-Finance Act, 2021, and the date of material transmission to the jurisdictional AO for non-searched entities. The court rejected the reconstruction of the "relevant assessment year" point for non-searched persons and found the notice issued on 30 March 2023 to be beyond limitation, thus quashing it and any consequential actions.

View Source

← Previous Next →

The Delhi High Court examined the validity of a reassessment ...

Validity of reassessment u/s 148 challenged - AY 2013-14 beyond block period - Notice quashed.

Case Laws Income Tax

June 3, 2024

You may also like:

The Income Tax Appellate Tribunal (ITAT) held that the reassessment notices issued u/s 148 of the Income Tax Act for the assessment years 2013-14, 2014-15, and 2015-16...

Validity of reopening of assessment - scope of old unamended law and new inserted section 148A - The High court held that notices issued under the newly inserted Section...

The High Court held that the Assessing Officer lacked jurisdiction to issue a notice u/s 148 on 25 July 2022 for the assessment year 2013-14, as the limitation period...

The High Court addressed the issue of reopening assessment u/s 147 and the time limit for notice u/s 149. The petitioner received a notice u/s 153C after a search...

Disallowance of sales tax liability - Prior-period item - the year under appeal is AY 2013-14. The alleged amount pertains to AY 2005-06 and AY 2010-11 and such...

Reassessment action initiated based on Section 148 notice and subsequent Section 148A(b) notice violated the First Proviso to Section 149(1) and was barred by the...

Acceptance of on-money in purchase of landed property, is relatable to the period relevant to the AY 2013-14. Perhaps only on account of fact that the sale deed was...

Section 153C provisions are inapplicable as notice was issued to 'other person' under this section. Computation of six-year block period preceding assessment year...

Exemption u/s 11 - AO made the addition on the ground that since the five years period expires in AY 2013-14, and since the assessee did not utilize the sum accumulated...

The High Court quashed the reassessment notices issued u/s 148 and the consequent initiation of reassessment proceedings, ruling in favor of the assessee. The key points...

Notice issued u/s 148 beyond the limitation period prescribed under erstwhile provisions of section 149(1)(b) is barred by limitation, even after considering the...

Validity of Reopening of assessment - The initial notices u/s 148 issued on 31st March, 2021 Section 151 of the Act as it stood prior to 1st April, 2021 would apply. In...

Addition u/s 68 - Cash credit surrendered - Income erroneously offered by the assessee in current AY - The above said credits/ amount were not received during the...

CIRP process - Permission sought from this Bench for carrying out the assessment proceedings for the assessment years A.Y. 2013-14 to A.Y. 2019-20 - the prayer of the...

Reopening of assessment u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint...

Quick Updates: