S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Audit objection-Review/change of opinion on the same material, which is impermissible-Notice and consequential orders were set aside-Notice issued under section 148 on 31-3-2023 was beyond four-year limitation under first proviso to section 149 as applicable, so extended six-year period did not apply, rendering such notice and subsequent proceedings invalid and liable to be quashed. [S. 147, 148, 148A(b), 148A(d),149, Art . 226]
Sapphire Foods India Ltd v. ACIT [2026] 309 Taxman 467 / 486 ITR 1 (Delhi)(HC)