Aarti Highrise Private Limited Vs JCIT (Calcutta High Court)
The Calcutta High Court quashed reassessment proceedings initiated against the petitioner for Assessment Year 2015-16, holding that the amended limitation provisions under Section 149 of the Income Tax Act, effective from 01.09.2024, applied to the case. The Court relied on the Supreme Court judgment in Income Tax Officer & Anr. vs Sri Sai Kumar Mateti, which had considered the earlier decision in Union of India & Ors. vs Rajeev Bansal.
The petitioner challenged the legality and validity of the show-cause notice dated 25.11.2025 issued under Section 148A(b), along with the order under Section 148A(d) and notice under Section 148 dated 29.01.2026 for AY 2015-16. The petitioner argued that after the amendment effective from 01.09.2024, the reassessment proceedings ought to have been governed by the amended provisions of Section 149.
Relying on the Supreme Court ruling in Sri Sai Kumar Mateti, the petitioner contended that notices relating to AY 2015-16 issued beyond the prescribed limitation period were liable to be struck down. The extracted portions of the Supreme Court judgment stated that if the case pertained to AY 2015-16, the notices would be time-barred in light of the decision in Rajeev Bansal.
