4 year limitation period for Re-Assessment is an Exception and not the Rule

1. This is yet another case in the ever increasing number of cases filed before this Court challenging the issuance of notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

Brief Facts

2. The Petitioner filed its return of income for the Assessment Year (‘AY’) 2008-09 declaring an income of Rs.1334,87,70,381/-. Its case was picked up for scrutiny and notice was issued to it under Section 143 (2) of the Act. As part of the scrutiny, a questionnaire dated 20t

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