Section 148 notice issued beyond statutory six-year limitation period is invalid: Bombay HC

Bhoomi Viral Shah Vs ITO (Bombay High Court)  In this case, the Bombay High Court examined a writ petition challenging multiple actions initiated under the Income-tax Act, including notices issued under Sections 148 and 148A, the reassessment order dated 26 May 2023 under Sections 147 read with 144 and 144B, demand notice, and subsequent penalty orders under Sections 271(1)(b), 271(1)(c), and 271F. The primary grievance raised was that the notice issued under Section 148 for Assessment Year 2013–14 was beyond the limitation period prescribed under Section 149. The petitioner contended that ...