Reassessment Notice for AY 2017-18 Invalid Due to Time-Bar Under Section 149

Cyberabad Citizens Health Services Private Limited Vs DCIT (Telangana High Court)

Reopening Under Section 148 Dated 22.04.2024 Held Invalid and Time-Barred Under the First Proviso to Section 149 for AY 2017-18

The Telangana High Court held that the Section 148 notice dated 22.04.2024 for AY 2017-18 was time-barred, since the six-year limitation under old Section 149(1)(b) expired on 31.03.2024, and the first proviso to amended Section 149 prohibits reopening beyond that date. The Court rejected the Revenue’s reliance on the fifth and sixth provisos, holdin

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