The notice u/s was 148 was issued on 31-8-2024. On writ the Court held that the period of six years from the end of the relevant assessment year 2016-17 expired on 31-3-2023 hence barred by limitation. Followed Manju Somani v. ITO [2024] 300 Taxman 516/466 ITR 758 (Delhi) (HC) (AY. 2016-17)
DB International Stock Brokers Ltd. v. ACIT (2025) 302 Taxman 405 (Delhi)(HC)
S. 149 : Reassessment-Time limit-Notice under section 148 dated 31-8-2024-Six years expired for the AY. 2016-17 the notice is quashed and set aside. [S. 148, Art. 226]
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