Calcutta HC Quashes S.148 Notices Barred by Limitation

Calcutta HC Quashes S.148 Notices Barred by Limitation

The Calcutta High Court has quashed several reassessment notices issued under section 148 of the Income Tax Act, citing limitation issues as the basis for its decision. The Court determined that the notices were issued beyond three years from the end of the relevant assessment year and lacked sufficient material to justify the assessment of income exceeding Rs. 50,00,000.

This ruling reinforces the statutory timelines stipulated by the Income Tax Act, emphasizing that adherence to these limits is crucial for valid reassessment procedures. The High Court's interpretation affirms taxpayer protections against arbitrary encroachments beyond regulatory constraints.

Practitioners must take heed of this decision, ensuring timely compliance with statutory timelines and preparing to contest any reassessment claims that may breach these limitations.