Bombay HC quashes 1377 Section 148 Notices issued after 31st March 21

Tata Communications Transformation Services Limited Vs ACIT (Bombay High Court)

The Division Bench of Hon. Bombay High Court consisting of K.R. SHRIRAM and N.J. JAMADAR, in Tata Communications Transformation Services vs. ACIT and Ors. WP 1334 of 2021 Order dated 29.03.22 quashed the reassessment notices issued after 31.03.21.

The Finance Act, 2021 introduced a new set of reassessment proceedings from 01.04.21.The Central Board of Direct Taxes (C.B.D.T)  by way of various notifications had extended the time limit of issuing the notice U/s 148 of the Act up to 30^th June, 2021.

The Income tax department has issued many Section 148 notices for several assessment years (A.Y. 2013-14 onwards) after 31^st March 2021.Many writ petitions have been filed across the country challenging the notices issued u/s 148 after 31st march 2021 and notifications issued by CBDT to extend the time limits for issuing such notices, various courts have also stayed the reassessment proceedings.

Earlier Hon. Chhattisgarh High Court in Palak Khatuja vs. UOI and others W.P.(T) 149 of 2021 had held the notice(s) issued after 31.03.21 to be valid.

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