SC Dismisses Revenue SLP in Time-Barred Reopening Case
In Mohd Athar Anjum v. Assistant Commissioner of Income Tax, the petitioner challenged a reassessment notice dated 31.03.2024 issued under Section 148, along with the order under Section 148A(d) and the final assessment order dated 15.03.2025 for AY 2016–17. The petitioner contended that the notice was barred by limitation, relying on the Supreme Court ruling in Union of India v. Rajeev Bansal. It was argued that under the old reassessment regime, the six-year limitation period from the end of AY 2016-17 expired on 31.03.2023, making the notice issued in March 2024 invalid.
<div class="related-article-inline">Also Read<a href="/supreme-court-clarifies-same-line-of-business-test-for-co-operatives-under-section-64d-417156.html" class="related-link">Supreme Court Clarifies “Same Line of Business” Test for Co-operatives under Section 64(d)</a></div>
Issue Before Court: Whether a reassessment notice issued under Section 148 after expiry of the statutory limitation period is legally sustainable ?
Supreme Court Held: The High Court allowed the writ petition and quashed the reassessment notice as well as the consequential assessment order. The Court held that the notice issued on 31.03.2024 was clearly time-barred, as the six-year limitation period had already expired on 31.03.2023. Notably, the revenue also conceded this position before the court.
<div class="related-article-inline">Also Read<a href="/supreme-court-grants-interim-stay-on-rs-1752-37-crore-gst-demand-against-delta-corp-419086.html" class="related-link">Supreme Court Grants Interim Stay on Rs 1,752.37 crore GST Demand Against Delta Corp</a></div>
The Supreme Court, while hearing the special leave petition filed by the revenue, condoned the delay but refused to interfere with the High Court's judgement. The bench of Hon’ble Justice J.B. Pardiwala and Hon’ble Justice Vijay Bishnoi found no reason to disturb the findings, thereby affirming that reassessment proceedings initiated beyond the permissible time limit are unsustainable in law.
To Read Full Judgment, Download PDF Given Below.

SC Dismisses Revenue SLP in Time-Barred Reopening Case
In Mohd Athar Anjum v. Assistant Commissioner of Income Tax, the petitioner challenged a reassessment notice dated 31.03.2024 issued under Section 148, along with the order under Section 148A(d) and the final assessment order dated 15.03.2025 for AY 2016–17. The petitioner contended that the notice was barred by limitation, relying on the Supreme Court ruling in Union of India v. Rajeev Bansal. It was argued that under the old reassessment regime, the six-year limitation period from the end of AY 2016-17 expired on 31.03.2023, making the notice issued in March 2024 invalid.
[related id="417156"]
Issue Before Court: Whether a reassessment notice issued under Section 148 after expiry of the statutory limitation period is legally sustainable ?
Supreme Court Held: The High Court allowed the writ petition and quashed the reassessment notice as well as the consequential assessment order. The Court held that the notice issued on 31.03.2024 was clearly time-barred, as the six-year limitation period had already expired on 31.03.2023. Notably, the revenue also conceded this position before the court.
[related id="419086"]
The Supreme Court, while hearing the special leave petition filed by the revenue, condoned the delay but refused to interfere with the High Court's judgement. The bench of Hon’ble Justice J.B. Pardiwala and Hon’ble Justice Vijay Bishnoi found no reason to disturb the findings, thereby affirming that reassessment proceedings initiated beyond the permissible time limit are unsustainable in law.
To Read Full Judgment, Download PDF Given Below.

SC reinforces strict adherence to limitation in reassessment proceedings under Income Tax Act.

SC Dismisses Revenue SLP in Time-Barred Reopening Case.

SC Dismisses Revenue SLP in Time-Barred Reopening Case

ITAT Holds Resale Price Method as Most Appropriate for Benchmarking Import of Finished Goods Without Value Addition

In a significant ruling, the ITAT quashed an income tax assessment after holding that the order attained legal existence only upon being digitally signed.

ITAT Holds Assessment Order Is Legally Complete Only After Digital Signature; Time-Barred Order Quashed

HC Denies Anticipatory Bail to Material Supplier in Alleged Nal-Jal Yojana Fraud Over Missing GST Bills and Invoices

ITAT Rules No TDS on Commission Paid to Overseas Agent for Procuring Export Orders 

ITAT Deletes Penalty under Section 270A for Vague Show Cause Notice Lacking Specific Charge

Income Tax Dept Removes ‘Other Exempt Income’ Option from ITR Forms, Revises Schedule EI for AY 2026-27

Bombay High Court upholds negative crude oil futures settlement, refusing to rewrite completed derivative contracts.

HC Upholds MCX Circular Fixing Negative Due Date Rate for Crude Oil

Bombay High Court quashes penalty after time-barred Order Giving Effect caused assessment proceedings to abate completely.

HC Holds Time-Barred Assessment Cannot Sustain Penalty Under Section 271(1)(c)

ITAT rules revocable determinate securitisation trust qualifies for pass-through taxation, rejecting assessment as an AOP.

ITAT Upholds Pass-Through Taxation for Revocable Securitisation Trust Under Income Tax Act

ITAT condones delay, restores Section 50C appeal after finding denial of adequate hearing by CIT(A).

ITAT Remands Section 50C Addition After Finding Breach of Natural Justice

ITAT allows Section 87A rebate on Section 111A gains for AY 2024-25, rejecting CPC's denial.