Hon’ble Supreme Court upheld the order passed by the Hon’ble Delhi High Court quashing the notice issued under section 148 of the Act beyond the period of six years from the end of relevant assessment year 2014 as barred by limitation. Further, as the escaped income involved was less than Rs. 50 lakhs, the benefit of the extended ten-year limitation period contemplated under section 149(1)(b) is not available to the Revenue. Hence, the reassessment notice is not sustainable. SLP of the Revenue dismissed. (AY. 2014-15)
ACIT v. Avinash Kumar (2026) 309 Taxman 167 (SC) Editorial: Avinash Kumar v. ACIT (2026) 182 taxmann.com 320 (Delhi)(HC)
S. 149: Reassessment-Time limit for notice-Notice under section 148 issued beyond the period of 6 years from the end of the relevant assessment year 2014-15 is barred by limitation-SLP of the revenue dismissed.[S. 148, Art. 136]
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