Notice u/s. 148A(d) issued beyond time prescribed u/s. 149(1)(a) is untenable-in-law

Baba Global Ltd Vs ACIT (Delhi High Court) Delhi High Court held that notice issued under section 148A(d) of the Income Tax Act beyond time limit prescribed under section 149(1)(a) is time-barred and accordingly, the notice and order thereon are set aside. Facts- The petitioner [Assessee] has filed the present petition. It is the petitioner’s case that the notice dated 27.04.2023 issued u/s. 148 of the Act [impugned notice] for Assessment Year [AY] 2019-20 is invalid as it was issued beyond the period of limitation. The last date for issuance of the notice was 31.03.2023. After accounting fo...