On a writ petition against a reassessment notice pertaining to the AY. 2015-16 issued on March 30, 2021, the High Court, in the light of the judgments of the Supreme Court in UOI v. Ashish Agarwal (2022) 444 ITR 1(SC)) and of the court in Ambika Iron and Steel Pvt. Ltd. v. PCIT (2023) 452 452 ITR 285 (Orissa)(HC), quashed the notice under section 148 of the Income-tax Act, 1961, issued prior to April 1, 2021, holding that it was beyond the period of six years after the expiry of the Assessment year. SLP of Revenue is dismissed. (AY. 2015-16)
ITO v. Salu Agarwal (2023)453 ITR 786/ 293 Taxman 454 (SC) Editorial: Refer Salu Agarwal v. ITO (2023)453 ITR 784 (Orissa)(HC)
S. 147 : Reassessment-Notice after six years-Notice issued prior to 1-4-2021 more than six years after expiry of Assessment year – High Court quashed notice and orders- SLP of Revenue is dismissed. [S. 148, Art. 136, 226]