Assessee challenged notice under section 148 and consequential order under section 148A(d) on ground that same was barred by limitation . Allowing the petition the Court held that all original notices issued under section 148 of old regime and issued between 1-4-2021 and 30-6-2021 would stand beyond prescribed timeline of six years from end of assessment years 2013-14 and 2014-15, thus would be time barred under old regime and could not be issued as per amended provisions . Followed , Keenara Industries Pvt Ltd. v. ITO ( SCA No. 17321 of 2021 dt . 07.2.2023, (AY. 2014 -15
Sunny Rashikbhai Laheri v. ITO (2023) 148 taxmann.com 438 (Guj)( HC)
S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – All original notices issued under section 148 of old regime and issued between 1-4-2021 and 30-6-2021 would stand beyond prescribed timeline of six years from end of assessment years 2013-14 and 2014-15- Assessment time barred under old regime and could not be issued as per amended provisions. [ S. 148 , 148A(b), 148A(d), 149, 151 , Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S.3 , Art , 226 ]