HC upheld the petition, declaring assessment notices for AY ...

Tax Assessment Notices Invalidated: Limitation Period Expired, Tribunal Order Beyond Statutory Timeframe Renders Notices Null and Void

April 30, 2025

Case Laws Income Tax HC

HC upheld the petition, declaring assessment notices for AY 2010-11 time-barred under Section 153(3). The Tribunal's order passed after 01 April 2019 extended the limitation period from 9 to 12 months. Calculating 12 months from the Tribunal's 21 October 2020 order revealed the jurisdictional authority expired on 21 October 2021. Consequently, the HC quashed the assessment notices dated 06 March 2023 and 19 March 2023 as legally impermissible, effectively invalidating any proposed transfer pricing adjustments beyond the prescribed statutory limitation.

View Source

← Previous Next →

HC upheld the petition, declaring assessment notices for AY ...

Tax Assessment Notices Invalidated: Limitation Period Expired, Tribunal Order Beyond Statutory Timeframe Renders Notices Null and Void

April 30, 2025

Case Laws Income Tax HC

You may also like:

Reopening of assessment u/s 147 - period of limitation extended to 16 years vide Finance Act, 2012- validity of notice for the period which has been expired already...

Extenuation of period of Limitation - Period for reopening of an assessment was already expired - extending the period of limitation from 5 years to 6 years to be not...

Re-assessment - Time limitation for notices issued - period of limitation enhanced from 5 years to 6 years - Prospective or retrospective amendment - 5 year period...

The High Court held that the limitation period prescribed in Section 153(3) of the Income Tax Act for issuing a fresh assessment order pursuant to an order u/s 254 (by...

Period of limitation to issue notice for reopening of assessment u/s 149 - The High court emphasized the principle that the validity of a notice u/s 148 must be assessed...

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...

The High Court held that the delay in issuing the tax refund was subject to the strict limitation period prescribed u/s 254 read with Section 153(3). The Assessing...

Validity of assessment order - The limitation for passing of such assessment order is four years from the end of the year containing the period to which the return...

HC held that despite considering three block periods of limitation exclusion as per SC precedents, the re-assessment notice dated 23 July 2022 exceeded statutory...

The ITAT held that the reassessment notice u/s 148 for AY 2014-15 and AY 2015-16 was time-barred. For AY 2014-15, the assessee failed to respond within the two-week...

Validity of orders under sec 201(1)/201(1A) - period of limitation - the limitation period for the financial year 2009- 10 relevant to assessment year 2010-11 expires on...

Validity of Reopening of assessment - period of limitation - Although the notice dated 30.06.2021 u/s 148 bears an endorsement at the foot of the page that it has been...

Validity of reopening of assessment u/s 147 - by the time, assessment order for the assessment year 2004-05 was passed on 31.12.2010, six year period for reopening of...

HC held that under Sections 292B and 292BB of the Income Tax Act, the assessee cannot challenge the validity of a notice u/s 143(2) or assessment order u/s 143(3) after...

Notices issued u/ss 84 and 27(1)(a) of the Tamil Nadu Value Added Tax Act, 2006 were valid. The time limitation for revising assessment orders is not an issue if a...

Quick Updates: