Shah Nanji Nagsi Exports Private Ltd. v. DCIT [2025] 175 taxmann.com 1067 (Bom) (HC)

S. 149: Reassessment-Time limit for notice-Notice under section 148 dispatched beyond the prescribed time-Notice quashed.[S. 148, 149(1), Information Technology Act, 2000, S. 13(1), Art. 226]

Where the notice under section 148 was digitally signed on 31-3-2021 but was dispatched on 1-4-2021, the High Court, applying section 13(1) of the Information Technology Act, 2000, held that the time limit prescribed under section 149(1) for issuance of notice had to be strictly complied with and, since the electronic record showed the sent time stamp as 1-4-2021, the notice was not issued within the prescribed limitation period and was liable to be quashed. (AY. 2014-15).

Leave a Reply

Your email address will not be published. Required fields are marked *

*