Verjinia Foods Limited Vs ITO (Bombay High Court)
Verjinia Foods Limited filed an Interim Application seeking further directions in Writ Petition No. 1428 of 2023 before the Bombay High Court, concerning reassessment proceedings for Assessment Year (A.Y.) 2015-16. The reassessment had been initiated by a notice under Section 148 of the Income-tax Act, 1961, issued on 5th April 2022. The petitioner had earlier filed the Writ Petition challenging these proceedings, and the Court, by order dated 9th May 2024, had quashed the reassessment notice. Despite this, the Assessing Officer continued proceedings and passed a reassessment order on 3rd March 2025 under Section 147, making an addition of ₹1,18,80,000, and issued notices under Section 156 along with penalty notices under Sections 271F, 271(1)(b), and 271(1)(c).
The Assessing Officer contended that proceedings were continued due to a pending Special Leave Petition (SLP) filed by the Revenue against the High Court’s May 2024 order. The Supreme Court disposed of the SLP, referencing its earlier judgment in Union of India v. Rajeev Bansal (2024), in which it was held that for A.Y. 2015-16, notices issued under Section 148 on or after 1st April 2021 are time-barred and must be dropped under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (“TOLA”).
