Calcutta HC Grants Stay on Reassessment Proceedings beyond 6 Years

RPC Commercial LLP Vs ACIT (Calcutta High Court)

RPC Commercial LLP has challenged a notice issued under Section 148 of the Income Tax Act for the assessment year 2015-16 and subsequent proceedings based on that notice. The petitioner argues that the assessing officer’s jurisdiction in issuing the notice is barred by limitation under Section 149(1)(a)/(1)(b) of the Act. The assessing officer justifies the initiation of proceedings based on an instruction issued by the Central Board of Direct Taxes (CBDT). The Calcutta

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