Allowing the petition the Court held that for the assessment year 2015-2016, the Assessing Officer issued a notice under section 148 of the Income-tax Act, 1961 digitally signing the notice on April 9, 2021 although it was dated March 31, 2021. The notice issued on April 9, 2021 was barred by limitation or lacked in jurisdiction since approval was granted by Joint Commissioner who was not the competent authority, notice and consequential order was quashed.(AY. 2015-16)
Rohit Kumar v. ITO (2025) 476 ITR 691 /170 taxmann.com 506 (Delhi)(HC)
S. 151 : Reassessment-Sanction for issue of notice-Specified authority-Grant of approval under section 151 to be in consonance with extended time limits Approval granted by Joint Commissioner not compliant with provisions Notice and assessment order invalid.[S. 147, 148, 149(1)(b), Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3, Art. 226]
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