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September 2024

Reassessment — Notice after three years — Limitation — Extension of limitation period under 2020 Act — Notice for A.Y. 2016–17 issued after April 2021 — Alleged escapement of income less than R50 lakhs — Notice barred by limitation

By Keshav Bhujle and Ritu Punjabi, Advocates
Reading Time 3 mins

SevenseaVincom Pvt. Ltd. vs. Principal CIT

[2024] 465 ITR 331(Jhar)

A.Y.: 2016–17

Date of order: 11th December, 2023

Ss. 147, 148, 149, 156 of the ITA 1961

43. Reassessment — Notice after three years — Limitation — Extension of limitation period under 2020 Act — Notice for A.Y. 2016–17 issued after April 2021 — Alleged escapement of income less than R50 lakhs — Notice barred by limitation.

The petitioner is a private limited company registered under the Companies Act, 2013. A notice dated 30th June, 2021 u/s. 148 of the Income-tax Act, 1961 for the A.Y. 2016–17 was issued to the petitioner. Thereafter, the Revenue issued a letter on 30th May, 2022 deemed to be a notice u/s. 148A(b) of the Act. However, no information and material relied upon by the respondent-Department were provided to the petitioner. Department passed the order on 21st July, 2022 u/s. 148A(d) of the Act and on the same date, i.e., 21st July, 2022 notice u/s. 148 of the Act was also issued for reassessment for the A.Y. 2016–17 and finally a reassessment order was passed on 31st May, 2023 against this petitioner and consequential notice of

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