The HC held that the period of limitation for reopening ...

Time Limit for Reopening Assessments Under Section 153C Must Be Calculated From End of Assessment Year When Notice Issued

March 29, 2025

Case Laws Income Tax HC

The HC held that the period of limitation for reopening assessments under Section 153C read with Section 153A must be calculated from the end of the assessment year relevant to the financial year in which the reopening action was initiated (i.e., when the Section 148 notice was issued). Since the assessment year in question (AY 2014-15) fell beyond the ten-year limitation period contemplated in these provisions, the Court allowed the petition and set aside the impugned notice as time-barred. This ruling clarifies how the block period for reopening assessments should be determined when applying limitation provisions.

View Source

← Previous Next →

The HC held that the period of limitation for reopening ...

Time Limit for Reopening Assessments Under Section 153C Must Be Calculated From End of Assessment Year When Notice Issued

March 29, 2025

Case Laws Income Tax HC

You may also like:

Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was...

Reopening of assessment u/s 147 - The High Court noted that the issue of disallowance under Section 14A of the Act had been thoroughly examined during the original...

Notice issued for reopening assessment u/s 147 was beyond the limitation period stipulated in Section 149(1). The High Court, following Ojjus Medicare Pvt. Limited,...

The final assessment order passed by the Assessing Officer u/s 147 read with Section 144C(13) for the Assessment Year 2016-17 is quashed as barred by limitation. Except...

Reopening of assessment u/s 147 - Time limit for notice - there is no document made available to prove that the notice under section 148 dated 31.03.2018 was sent for...

Reopening of assessment u/s 147 was based on reasons to believe the difference between total cash sales and cash sales reflected in books. Held: Reopening was made only...

Validity of reopening of assessment - time limit for issue of notice u/s. 143(2) has not expired and regular assessment could have been made - the assessing officer...

This case involves a challenge to an order of re-assessment under the relevant tax laws. The key points are: The petitioner failed to submit monthly returns within the...

Reopening of assessment u/s 147 - Time limit for notice to be issued u/s 149 - escaped income from an asset outside India - there is no bar on the retrospectivity of a...

Validity of reopening of assessment - notice against non existent entity / amalgamated company - Notices issued.

A notice for reopening assessment for AY 2014-15 could not be issued beyond the period of six years. Uploading of information by the investigation wing would not...

The case pertains to the jurisdiction of impugned orders under the U.P.G.S.T. Act, 2017, and the time limitation u/s 73 and Section 44 of the Act. The key points are:...

Reassessment proceedings initiated beyond statutory time limit prescribed under pre-amended Section 149(1)(b) quashed. Notice u/s 148 issued after expiry of six-year...

Reopening of assessment u/s 147/148 - failure to issue notice u/s 143(2) - reopening of assessment is not valid as the Income Tax Department has power to conduct the...

Validity of the notice issued u/s. 143(2) - statutory time limit to issue notice - the AO has issued notice u/s. 143(2) on 12/10/2020 after expiry of six months from the...

Quick Updates: