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18. Hitesh Ramniklal Shah vs. Assistant Commissioner of Income Tax-23(1),Mumbai & Ors.
[WP No. 4164 OF 2025, Dated: 11/11/2025. (Bom) (HC)]
Section: 148
Reassessment – period of limitation - “surviving period” - Effect of UOI vs. Ashish Agarwal [444 ITR 1 (SC)] & UOI vs. Rajeev Bansal [ 469 ITR 46 (SC):
The Petitioner challenges a notice dated 27 July 2022 issued under Section 148 of the Income-tax Act, 1961, the subsequent notices issued by Respondent No.1, inter alia on the ground that the notice under Section 148 of the Act is issued beyond the period of limitation, and therefore, all subsequent notices will also be bad in law.For the year under consideration, i.e. the A.Y. 2014-15, the Petitioner filed his return of income on 29 September 2014 declaring a total income of r64,86,660/- in respect of which no scrutiny assessment was made. Respondent No.1 issued a notice dated 29 June 2021 under the unamended provisions of Section 148 of the Act, after obtaining the approval of the Principal Commissioner of Income Tax, Mumbai-19. The Petitioner filed his return of income on 18 November 2021 in response to the notice issued under Section 148 of the Act declaring the same income that was declared in the original return
