Ved Prakash Mittal v. UOI (2022) 449 ITR 321 (Cal.)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Order for issue of notice after six years-Barred by limitation-Order was quashed. [S. 147, 148, 148A(d), Art. 226]

The assessee filed the writ petition challenging the order passed under section 148A(d) is beyond limitation. Allowing the petition the Court held that the order under section 148A(d) of the Income-tax Act, 1961 dated July 29, 2022, relating to the assessment year 2014-15 on the ground that it was without jurisdiction and barred by limitation since the reopening of the assessment had been made admittedly after six years from the end of the expiry of the period of the relevant assessment year. (AY.2014-15)