Delhi HC Clarifies Limitation Period for Reassessment Notices Issued under Amended Section 149 after...

The Delhi High Court has clarified the limitation period for reassessment notices issued under the amended Section 149 of the Income Tax Act, especially in light of the TOLA (Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act) extensions. The court stated that the time limit prescribed under Section 149 is a "hard stop," and the Assessing Officer must complete the entire procedure for issuing a notice under Section 148 within this period. This decision provides significant clarity and protection to taxpayers, reinforcing that extensions related to the COVID-19 pandemic do not grant indefinite power to the tax authorities to initiate reassessment proceedings.