Held, allowing the petition, that the notice issued under the pre amended provisions of section 148, after the amendment with effect from April 1, 2021, for the assessment year 2014-2015, was barred by limitation under section 149 and accordingly quashed. The order was restricted only to the point of limitation since the notice had been issued after the amendment by the Finance Act, 2021, on April 1, 2021, and that too under the provisions existing prior to the amendment.(AY. 2014-15)
Bela Kishor Varma v. PCIT(2025) 483 ITR 793 (Bom)(HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Directions issued by Supreme Court in UOI v. Ashish Agarwal. Notice barred by limitation. Notice quashed and set aside [S. 147, 148, 148A(b) 148A(d), 149, Art. 226]
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