Notice issued u/s 143(2) after 6 months from end of financial year in which return is furnished is time barred

SMC Comtrade Ltd Vs ACIT (Delhi High Court) Delhi High Court held that notice issued under section 143(2) of the Income Tax Act after the expiry of six months from the end of the financial year in which return is furnished is barred by limitation and hence unsustainable in law. Facts- The petitioner/assessee had filed its original Return of Income (ROI) on 14.10.2016. In the ROI, the petitioner/assessee declared a loss amounting to Rs. 3,85,73,772/-. On 06.02.2017, the petitioner/assessee was served with a notice u/s. 139(9). This notice stated that the ROI filed by the petitioner/assessee was...