20 Media Collective Pvt. Ltd.v Pr. ACIT (Bom) (HC)(UR)

S.148: Reassessment-Notice-Barred by limitation-Notice and order is quashed. [S.149(1)(b), Art. 226] Assessment year 2015-16-Barred by limitation (A.Y. 2015-16)

The Assessee-Petitioner challenged the legality of the notice issued under Section 148 of the Act for the A.Y. 2015-16. on the ground that the proceedings were barred by limitation, considering the provisions of Section 149(1)(b) of the  Act which provides a time limit of six years from the end of the relevant assessment year for issuing notice under Section 148 of the Act. As the relevant assessment year is assessment year 2015-16 the six years has expired on 31 March 2022 and for such reason, the impugned proceedings against the Petitioner could not have been adopted. In support of such contention, reliance is placed on the decision of this Court in Hexaware Technology Ltd. v. ACIT  (2024) 162 Taxmann.com 225 (Bom)(HC),  Akhila Sujith  v.. ITO(IT) [2024] 166 taxmann.com 478 (Bom)(HC). [WP (L) No. 25601 of 2024, Dated: 18/11/2024 (AY. 2015-16)