Rubina Senapati v. NAFC (2022) 449 ITR 333 (Orissa)(HC)

S. 148 : Reassessment-Notice-Limitation-Notice issued beyond six years from the end of the assessment year barred by limitation-Proceedings and demand notice was quashed. [S. 147, Art. 226]

Allowing the petition the Court held that notice dated March 31, 2021 under section 148 of the Income-tax Act, 1961 seeking to reopen the assessment for the assessment year 2013-14, being beyond the period of six years from the end of the relevant assessment year, was barred by limitation, and therefore, quashed. All proceedings consequential thereto including the assessment order and the consequential demand notice under section 156 were also quashed. (AY.2013-14)