Sree Narayana Guru Memorial Educational and Cultural Trust v. ACIT (2025) 478 ITR 466 (Ker)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Law applicable-Effect of amendment of section 148 with effect from 1-4-2022-Audit objection could form basis of notice.[S. 147,148, 148A(b), 148A(d), Art. 226]

The provisions relation to reassessment have been changed drastically changed with effect from April 1, 2022, section 148 of the Income-tax Act, 1961, has been amended and clause (ii) of Explanation 1 has been inserted which provides that any audit objection to the effect that the assessment in the case of an assessee for the relevant assessment year has not been made in accordance with the provisions of the Act would be a ground for reopening of the assessment. (SJ) (AY. 2016-17)

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