EASH KUMAR SARNA, VS ITO, WARD -1, AND SEEMA RANI SARNA, VS. ITO, WARD -1
Parties Involved
Facts Summary
These appeals were filed by Eash Kumar Sarna and Seema Rani Sarna against the orders of the Ld. CIT(A)/NFAC, Delhi. The assessment orders were framed by the AO/NFAC, Delhi for the Assessment Year 2015-16 under sections 147 read with section 144B of the Income Tax Act, 1961. The assessees raised jurisdictional issues regarding the assumption of jurisdiction by the AO for reopening the assessment under sections 147 and 148 of the Act. The notice under section 148 of the Act dated 22.07.2022 was argued to be barred by limitation as it was issued after the expiry of 6 years from the end of the relevant assessment year, i.e., AY 2015-16.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the notice issued under section 148 of the Act dated 22.07.2022 is barred by limitation.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
4 precedents cited in this judgement.
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