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IN THE HIGH COURT OF KARNATAKA AT BENGALURU
S.R.KRISHNA KUMAR
Sunvik Steels Pvt. Ltd. – Appellant
Versus
Deputy/Assistant Commissioner Of Income Tax, Circle 6(1)(1), Bangalore – Respondent
ORDER :
S.R.KRISHNA KUMAR, J.
In this petition, the petitioner seeks the following prayer:
"i. Quashing the impugned order dated 28.07.2022 bearing the 1st ITBA/COM/F/17/2022-23/1044244818(1) passed by the 1st Respondent under Section 148A(d) of the Income-tax Act, 1961, for the assessment year 2013-14 (Annexure 'A');
ii. Quashing the impugned notice dated 28.07.2022 and the accompanying document dated 29.07.2022 bearing ITBA/AST/S/91/2022-23/1044284519(1) issued by the 1st Respondent under Section 148 of the Income-tax Act, 1961, for the assessment year 2013-14 (Annexures 'B-1' and 'B-2'); iii. Declaring that the impugned proceedings initiated by the 1st Respondent under Section 147 read with Sections 148 and 148A of the Act are barred by limitation and opposed to the said provisions and are, therefore, without jurisdiction;
iv. Quashing the impugned Instruction bearing No.1/2022 dated 11.05.2022 issued by the 6th Respondent (Annexure C) to the extent that the same purports to direct that fresh notices under S.148 can be issued for AY 2013-14 so long as the quantum of income alleged to have escaped assessment is more than Rs.50 lakhs, without having regard to the express limitation p
Notices issued beyond the limitation period established by the Income-tax Act and relevant Supreme Court directives are deemed invalid.
Notices issued beyond the established statutory limitation are invalid and must be quashed, emphasizing compliance with timelines set by legal precedents in tax law.
Notices issued under the Income Tax Act beyond the statutory limitation set by Supreme Court precedents are invalid and must be quashed.
Notices and orders issued under the Income Tax Act were quashed as time-barred, adhering to Supreme Court mandates on limitation periods.
Notices under Section 148 of the Income Tax Act issued beyond prescribed limitation are invalid as per Supreme Court directives.
Notices issued under sections 148 and 148A(d) of the Income Tax Act beyond the specified limitation period are invalid and subject to quashing.
Notices issued under Section 148 of the Income Tax Act are invalid if they are issued beyond the stipulated 'surviving time' as established by the Apex Court, necessitating adherence to prescribed li....
Notices issued for reassessment under the Income Tax Act must adhere to statutory time limits; those issued beyond the time limit are considered invalid.
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