Delhi HC Quashed Reopening Notice as Issued Beyond Six-Year Limitation

Mohd Athar Anjum Vs ACIT (Delhi High Court) Reopening u/s 148 beyond six years from end of AY 2016–17 held time-barred; notice and consequent assessment quashed in view of limitation under proviso to Section 149 as clarified in Union of India v. Rajeev Bansal. Core Issue: Whether a notice issued under Section 148 of the Income Tax Act, 1961 for AY 2016–17 after expiry of six years from the end of the relevant assessment year is barred by limitation in view of the first proviso to Section 149(1), and whether such time-barred cases can be reopened under the new reassessment regime. Read SC ...