20 May 2022
Mr.A received notice u/s 148 for the assessment year 2013-14 as on notice dated 31.03.2021 but the notice was digitally signed on 15/04/2021 .
As per the latest judgment of H'nble Supreme court state that reassessment notices issued under old law shall be deemed to be notices issued under new law.
Here sec 149 state that As per substituted section 149, no notice shall be issued for the relevant assessment year if: (a) 3 years have elapsed from the end of the relevant assessment year, unless the case falls under clause (b) below
(b) If 3 years, but not more than 10 years, have elapsed from the end of the relevant assessment year unless the Assessing Officer has in his possession books of account or other documents or evidence which reveal that the income chargeable to tax, represented in the form of asset, which has escaped assessment amounts to or is likely to amount to INR 50 Lakhs or more for that year.
This limit of 50 lakhs apply to old notices also or not ?
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