Allowing the petition the Court held that the notices issued for the assessment years 2013-14 and 2014-15, under section 148 of the Income-tax Act, 1961 referable to the old regime and issued between April 1, 2021 and June 30, 2021 would stand beyond the prescribed permissible timeline of six years from the end of the assessment years 2013-14 and 2014-15. Hence all such notices relating to the assessment years 2013-14 and 2014-15 would be time-barred in terms of the provisions of the Act as applicable in the old regime prior to April 1, 2021. These notices could not be issued under the amended provisions of the Act. Referred Keenara Industries Pvt Ltd v.ITO (2023) 453 ITR 51 (Guj)(HC), Rajeev Bamsal v.UOI (2023) 453 ITR 153 (All)(HC) (AY.2013-14, 2014-15)
Jain Chain v. ITO (2023)457 ITR 526 (Guj)(HC)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notices issued on or after 1-4-2021-Beyond six years from end of relevant assessment year-Barred by limitation. [S. 148, 148A(b), 148A(d) 149(1), Art. 226]