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October 2024

Reassessment — Notice —Limitation — Amendment in law — Effect of amendment with effect from 1st April, 2021 — Notices dated 31st March, 2021 but dispatched on 1st April, 2021 or thereafter from Income-tax Business Application Portal — Notices barred by limitation.

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

49 KalyanChillara vs. DCIT

[2024] 465 ITR 729(Telangana)

Date of order: 14th June, 2024

Ss.147, 148, 149 and 151 of the ITA 1961

Reassessment — Notice —Limitation — Amendment in law — Effect of amendment with effect from 1st April, 2021 — Notices dated 31st March, 2021 but dispatched on 1st April, 2021 or thereafter from Income-tax Business Application Portal — Notices barred by limitation.

This judgment deals with a batch of petitions which were before the Hon’ble Telangana High Court challenging the notices issued u/s. 148 of the Act.

In all these writ petitions, the last date of service of notice and initiating proceedings for re-opening of assessment was coming to an end on 31st March, 2021. In majority of the cases, the notice issued u/s. 148 was dated 31st March, 2021. However, the notices have been issued from

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