Reassessment notice issued u/s. 148 beyond six years is time barred: ITAT Mumbai

ACIT Vs Orbit Financial Capital (ITAT Mumbai) ITAT Mumbai held that notice under section 148 of the Income Tax Act issued after a period of six years is barred by limitation. Accordingly, assessment proceedings under section 147 is liable to be quashed. Facts- The assessee is a partnership firm and vide cross objection assessee has mainly contested that entire re-assessment proceedings under section 148 of the Income Tax Act is barred by limitation. Conclusion- Held that the notice u/s.148 issued on 27/07/2022 is clearly barred by limitation. The reason being the test for checking the time lim...