Notice u/s 148 of Income Tax Act Issued Beyond Limitation Period: Delhi HC Sets Aside Proceedings

The Delhi High Court set aside income tax proceedings under Section 148, ruling the notice was issued beyond the six-year limitation period without valid justification. Justice Rajiv Shakdher found the department failed to demonstrate that income escaping assessment exceeded ₹50 lakh, which is necessary for extended limitation. The case involved reopening of AY2016-17 based on third-party information about alleged undisclosed transactions. The judgment strictly enforces limitation periods under Section 149, preventing endless exposure to tax scrutiny. Taxpayers can now challenge belated reopenings where authorities don't quantify alleged evasion or establish jurisdictional prerequisites. This brings certainty to tax litigation timelines while allowing legitimate reopenings within statutory deadlines.