Deciding two connected writ petitions arising from a common Industrial Tribunal Award, the Delhi High Court set aside the Tribunal's direction granting hotel workmen a further…
Assessment Proceedings u/s 153C of Income Tax Act initiated after 10 Years Block Period is Invalid: Delhi HC
The Delhi High Court ruled that initiating assessment proceedings under Section 153C of the Income Tax Act beyond the 10-year block period is unsustainable. Flowmore Limited challenged a notice under Section 148 for the Assessment Year 2013–14, issued on March 31, 2023, under the amended reassessment regime effective from April 1, 2021. \r
The petitioner was initially served a notice under Section 153C on March 3, 2022, following a search on October 18, 2019. The final assessment on March 23, 2023, upheld the original income assessed under Section 143(3). \r
The court observed that action for reassessment must comply with Section 149(1)(b) and noted AY 2013–14 falls beyond the allowable period, rendering the notice invalid.