SVR Creations Pvt. Ltd. vs. The PCIT

Parties Involved

Facts Summary

The case involves SVR Creations Pvt. Ltd. challenging the reassessment order passed by the Principal Commissioner of Income Tax (PCIT) for Assessment Year 2016-17. The reassessment was initiated under section 148 of the Income Tax Act, 1961, following the reopening of the assessee's case. The reassessment order accepted the income declared by the assessee. Subsequently, proceedings under section 263 of the Act were initiated by the PCIT, leading to a direction to modify the assessment order. The assessee argued that the reassessment order was invalid as it did not follow the amended provisions of section 148, which came into effect on 01/04/2021. The notice under section 148 was issued on 31/03/2021 but received by the assessee on 01/04/2021, after the amendments took effect.…

Legal Issues

• 1. Validity of the initiation of reassessment proceedings under section 148 of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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