Delhi HC Quashed Reassessment Notice as Time-Barred for Crossing Ten-Year Limit

Pankaj Jain Vs ACIT (Delhi High Court)

The Delhi High Court considered a writ petition challenging a notice issued under Section 148 of the Income-tax Act, 1961 for Assessment Year (AY) 2015–16. The petitioner confined the challenge to the ground of limitation, contending that the reassessment notice was time-barred. The Court noted that where reassessment proceedings arise from a search conducted on or after 01.04.2021, the action must satisfy the limitation framework under Sections 149, 153A and 153C as they existed prior to the Finance Act, 2021, by virtue of the first proviso

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