Section 148 Notice Procedure Must Be Completed Within Section 149 Timeframe: Delhi HC

Ram Balram Buildhome Pvt. Ltd. Vs ITO And Anr. (Delhi High Court) Delhi High Court held AO is required to complete the entire procedure for issuance of notice under Section 148 of the Act within the period as prescribed u/s. 149 of the Act. Thus, if AO is unable to complete such procedure within the period of limitation, the AO would cease to have the jurisdiction to issue such a notice. Facts- The petitioner has filed the present petition under Article 226 of the Constitution of India, inter alia, impugning (i) a notice dated 01.06.2021 issued under Section 148 of the Income Tax Act, 1961; (i...