The assessee challenged the notice dated 30-7-2022 issued under section 148 for AY 2015-16. Since six years from the end of AY 2015-16 had expired on 31-3-2022, proceedings initiated thereafter were barred by the first proviso to section 149. Consequently, the order under section 148A(d), notice under section 148 and the consequential assessment order were quashed and set aside. (AY. 2015-16)
120 Media Collective (P.) Ltd. v. ACIT [2025] 170 taxmann.com 331 (Bom.)(HC)
S. 149: Reassessment-Time limit for notice-limitation period of six years from the end of the relevant assessment year 2015-16 expired on 31-3-2022, notice under section 148 issued on 30-7-2022 was barred by limitation and proceedings under sections 148A and 147 were quashed. [S. 147, 148,148A(d), 149(1)(b), Art. 226]
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