Evergreen Infrasolutions (P.) Ltd. v. ACIT (2025) 305 Taxman 497 (Delhi)(HC)

S. 148 : Reassessment-Notice-Block period-Satisfaction note was recorded on 27-8-2024-Assessment year 2014-15 fell beyond ten-year block period and, therefore, impugned notice issued under section 148 was barred by limitation.[S. 132,148A(b), 148A(d), 158BC, Art. 226]

Assessee-company, engaged in business of construction and other related activities, had filed its return of income declaring certain income.  Subsequently, a search was conducted in case of one Kala Rathi, RSW Steel Ltd  wherein it was found that assessee had made fictitious purchases from Kala Rathi.  On basis of same, Assessing Officer issued a notice under section 148 in case of assessee on 31.8.2024.Assessee filed  writ petition contending that satisfaction note of Assessing Officer exercising jurisdiction in respect of assessee was recorded on 27.8.2024. Court held that since satisfaction note was recorded during financial year 2024-25, period of ten years was required to be considered from end of assessment year 2025-26 and, thus, assessment year 2014-15 fell beyond ten-year block period  therefore, impugned notice issued under section 148 was barred by limitation. (AY. 2014-15)

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