| Question And Answer | |
|---|---|
| Subject: | 148A ORDER AY 18-19 ON 6/4/22 |
| Category: | Income-Tax |
| Querist: | RAJEY |
| Answered by: | Advocate Shashi Ashok Bekal |
| Tags: | Notice, Reassessment |
| Date: | April 8, 2022 |
The assessee company recd 148A notice in March 2022.The assessee replied.Matter was of 25 lakhs. 148A order dated 6/4/22 came on 6/4/22.Notice u/s 148 also issued dated 6/4/22. Is it valid notice .148 notice is time barred on 31/3/22 for AY 18-19 of below 50 lakhs matter.Experts opinion awaited,What should be assessee next course of action.
Yes, it is a valid Notice, since the reassessment is within 3 years from the end of the AY i.e., AY 18-19, the pecuniary limit of Rs. 50 lakhs will not apply.
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I think that the notice u/s 148 ought to have been issued within 3 years from the end of the assessment year to which the escaped income related, as the income escaped assessment was Rs.25 lacs. Here in this case the escaped income relates to AY 2018-19 therefore three years to be reckoned from 31.03.2019 which ended on 31.03.2022 and therefore the notice u/s 148 issued on 06.04.2022 is barred by limitation.
time limit under 148A is vital