The High Court held that the validity of a notice under section 148 must be judged on the basis of the law existing on the date of its issuance. The deadline for issuance of such a notice had expired on 31.03.2021. Consequently, the notice issued on 25.07.2022 was held to be hopelessly barred by limitation and was quashed. (AY. 2014-15)
Gandhi Commodities LLP v. UOI [2024] 167 taxmann.com 436 (Bom.) (HC)
S. 149 : Reassessment-Time limit for notice-For AY. 2014-15, deadline expired on 31.03.2021-Notice issued on 25.07.2022 is barred by limitation. [S. 148, 148A(b), 148A(d), Art. 226]
Leave a Reply