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December 2024

Section 148: Reassessment — Assessment year 2015–16 — Barred by limitation.

By Ajay R. Singh, Advocate
Reading Time 3 mins

19 20 Media Collective Pvt. Ltd. vs. Pr. ACIT Circle - 16(1) &Ors.

[WP (L) No. 25601 OF 2024,

Dated: 18th November, 2024 (Bom) (HC)]

Section 148: Reassessment — Assessment year 2015–16 — Barred by limitation.

The Assessee-Petitioner challenged the legality of the notice dated 30th July, 2022 issued to the Petitioner under Section 148 of the Income-tax Act for the Assessment Year 2015–16.

There is also a challenge to an order dated 29th July, 2022 passed under Section 148A(d) of the Act passed in pursuance of a notice under Section 148A(b), dated 17th June, 2021 and the consequent assessment order dated 17th May, 2023 passed under Section 147 read with 144B of the Act.

The primary contention urged on behalf of the petitioner is that the impugned assessment order, as also the action taken against the petitioner under Section 148A(b), is illegal for the reason that such proceedings were barred by limitation, considering the provisions of Section 149(1)(b) of the Act, which provides a time limit of six years from the end of the relevant assessment year for issuing notice under Sect

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