SARIKA KANSAL Vs. ASSISTANT COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) The petitioner has filed the present petition impugning an order dtd. 22/4/2024 (hereafter the impugned order) passed under Sec. 148A(d) of the Income Tax Act, 1961 (hereafter the Act) as well as the notice dtd. 22/4/2024 (hereafter the impugned notice) issued under Sec. 148 of the Act in respect of assessment year (AY) 2017-18.

(2.) The petitioner's challenge to the impugned order and the impugned notice is two-fold. First, that the impugned order has been passed without considering that the information on the basis of which it is premised was the subject matter of reassessment proceedings, which culminated in an order dtd. 29/3/2022 passed under Sec. 147 read with Sec. 144B of the Act. The petitioner's contentions were accepted, and no addition was made. The petitioner contends that assessment cannot be opened twice for the same reason.

(3.) The second ground is that the impugned notice is beyond the period of limitation. According to the petitioner, the limitation for issuance of the impugned notice expired on 31/3/2024.