Reassessment Notice Under Section 148 Invalid If Issued After Four Years

NTPC Ltd. Vs DCIT (ITAT Delhi)

Reassessment notice issued under Section 148 is invalid, if it is issued after the four-year of relevant assessment year

The assessee, NTPC Ltd, had filed its original return of income for the assessment year 2006-07 on November 14, 2006. The return was processed under Section 143(1) of the Income-tax Act, 1961. Subsequently, the assessee filed a revised return on March 20, 2007. The assessment was completed under Section 143(3) on November 26, 2007.

During the audit, certain discrepancies were noticed by the Revenue Audit Party, which were communicated to the assessee on September 8, 2008. The assessee replied to the audit objections on September 11, 2008. However, the Revenue did not respond to the assessee’s reply.

Reassessment Notice

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