Bombay HC stays reassessment notice after expiry of a period of six years

Dilipkumar Premji Chheda Vs ITO (Bombay High Court)

1. Issue notice. Mr. Ajeet Manwani, learned counsel waives service for the Respondents. Objections be filed in six weeks.

2. Learned counsel for Petitioner states that the impugned notice dated 7^th April, 2021 issued under Section 148 of the Act is unsustainable in law and in as much as it is issued after expiry of a period of six years prescribed in terms of the first proviso to Section 149 of the Act.

3. List on 10^th October, 2022.

4. In the meantime, ad-interim relief granted earlier shall continue to operate till the next date.