Sanjay Singhal v. ACIT (2025) 303 Taxman 35 (Delhi)(HC)

S. 150 : Assessment-Order on appeal-Reassessment-Time limit for notice-No finding or direction-Notice issued beyond limitation-Quashed.[S. 69A, 148, 148A(3), 149(1), 153A, Art. 226]

Pursuant to search proceedings, additions under section 69A were made and later deleted by CIT(A) and confirmed by the Tribunal; the High Court dismissed revenue’s appeal. AO then issued notice under section 148A(b) followed by order under section 148A(3). The Court held that the earlier High Court order could not be construed as “finding or direction” under section 150 to permit issue of notice beyond the limit in section 149(1). The notice and order were quashed as time-barred. (AY. 2015-16)

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