Allowing the petition the High Court held that the reassessment notice was issued beyond limitation period of six years after end of assessment and consequential orders are set aside. SLP of Revenue is dismissed in view of Circular No. 17/2019 dated 8-8-2019, amount of tax involved was low. Issue is kept open.
ITO v. K. Devasis Patro (2023) 294 Taxman 343 (SC) ITO v. Tapan Kumar Ghadei (2023) 455 ITR 356 /294 Taxman 522 (SC) Editorial: K. Devasis Patro v.ITO (2023) 153 taxmann.com 197 (Orissa) (HC) / Tapan Kumar Ghadei v. ITO (2023) 153 taxmann.com 576 (Orissa)(HC)
S. 148 : Reassessment-Notice-Beyond period of limitation-Notice and consequential order was quashed-SLP of the Revenue is dismissed due to low tax effect-Issue is kept open. [S. 147, 149, Art. 136]