Yashashvi Securities Private Limited Vs ACIT (Calcutta High Court)
Reassessment Notice for AY 2015-16 Challenged as Time Barred; Calcutta HC Grants Interim Relief; Calcutta HC Examines Validity of Section 148 Notice Because Limitation Under Old Regime Had Expired; Revenue Restrained From Coercive Steps in Alleged Time-Barred Reassessment Proceedings; Calcutta HC Hears Dispute on Ten-Year Reassessment Window for AY 2015-16; Section 148 Notice Issued After Search Action Faces Limitation Challenge Before Calcutta HC; Calcutta HC Considers Impact of Rajeev Bansal Ruling on AY 2015-16 Reassessment Proceedings; Interim Relief Granted in Reassessment Case Because Assessee Claimed Proceedings Were Without Jurisdiction.
The Calcutta High Court heard a writ petition challenging reassessment proceedings initiated under Section 148 of the Income Tax Act for Assessment Year 2015-16. The petitioner challenged the notice dated 04.12.2024, subsequent notices under Sections 143(2) and 142(1), and the show cause notice dated 27.02.2026.
The petitioner submitted that it had originally filed its return for AY 2015-16 on 30.09.2015 declaring nil income, following which scrutiny assessment under Section 143(3) had already been completed. Subsequently, a search under Section 132 was conducted on 15.06.2023 in the case of Shyam Steel Udyog Private Limited and associated entities, including the petitioner’s premises.
Pursuant to the search, the Revenue issued notice under Section 148 on 04.12.2024. The petitioner filed a return under protest and later objected to notices issued under Section 142(1). The objections were rejected, leading to challenge of the subsequent show cause notice.
