Notice u/s 148 beyond the period of six years is barred by limitation

Shree Durgasyntex Private Limited Vs ACIT (Gujarat High court) Gujarat High Court held that issuance of notice for reassessment under section 148 of the Income Tax Act beyond the period of six years from the end of the relevant assessment year is barred by limitation. Facts- In the present petition filed under Article 226 of the Constitution, the petitioner has called in question the notice dated 31.07.2022 issued by respondent-assessing officer under Section 148 of the Income Tax Act, 1961 seeking to reopen the assessment in respect of assessment year 2013-14. Also challenged is the order dat...