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2022 (5) TMI 419 - HC - Income TaxValidity of reopening of assessment u/s 147 - Period of limitation to initiate reopening - notice issued time barred - HELD THAT:- As the notice under Section 148 of the Income Tax Act, 1961 was issued by the respondent no. 2 to the petitioner on 01.04.2021 at 05:30:08 AM which was delivered on the same date at 05:30:11 AM. Limitation available to the respondents to issue notice under Section 148 of the Act, 1961 for the assessment year 2013-14 was available only till 31.3.2021.In view of the aforesaid, we direct the respondents to file a counter affidavit within two days annexing therewith all the relevant papers showing issue of notice as well as copy of the order-sheet either physical or online. Put up as a fresh case on 7.4.2022 at 10:00 AM. As an interim measure, it is provided that all further and consequential proceedings pursuant to the impugned notice under Section 148 of the Act, 1961 shall remain stayed until further orders of the Court.
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