Notice u/s. 148 cannot be issued after expiry of four/six years: Delhi HC

Manju Somani Vs ITO (Delhi High Court) Delhi High Court held that that no notice under section 148 of the Income Tax Act shall be issued if four years “but not more than six years” have elapsed from the end of the relevant assessment year. Facts- The principal challenge is to the initiation of reassessment pursuant a notice dated 29 April 2024 issued u/s. 148 of the Income Tax Act, 1961 and pertaining to Assessment Year 2016-17. The reassessment action represents the third foray of the writ petitioner consequent to an earlier action coming to be annulled. The petitioners contend that beari...