Section 148 Notice Uploaded After Limitation Time-Barred: Calcutta HC

ACIT Vs Radhakrishna Bimalkumar Private Limited (Calcutta High Court) The Revenue filed an appeal against the order of the Single Judge allowing the assessee’s writ petition challenging a notice issued under Section 148 of the Income-tax Act, 1961. The appeal was filed with a delay of 426 days. Although the explanation for the delay was not fully satisfactory, the High Court condoned the delay since the appeal involved a question of law. The principal issue before the Court was whether the notice issued under Section 148 was barred by limitation. The Single Judge had found, on examining ...