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2022 (5) TMI 420 - HC - Income TaxReopening of assessment u/s 147 - Period of limitation to initiate reopening - notice issued time barred - HELD THAT:- In view of the facts admitted by the respondents in the short counter affidavit that the date and time of triggering of email automatedly by ITBA technical servers is at 01/04/2021 05:30:08 a.m., the impugned notice under Section 148 of the Income Tax Act, 1961 dated 31.03.2021 is without jurisdiction, inasmuch as it has been issued by the respondents on 01.04.2021, i.e., after expiry of the limitation for issuing notice. The controversy involved in this petition is concluded by our judgment in Daujee Abhushan Bhandar Pvt. Ltd. vs. Union of India & 2 Ors. [2022 (3) TMI 784 - ALLAHABAD HIGH COURT] - Reassessment notice set aside - WP allowed.
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