INDIA: The Unanswered Question of Limitation– A Contentious Issue Post Supreme Court ruling on Reassessment Controversy

The Finance Act 2021 altered the scheme of reassessment substituting Sec. 147 to Sec 149 and Sec. 151 of the Act. The substituted Sec. 149 of the Act has curtailed the time limit for issuance of notice u/s 148 to 3 years (where the alleged concealment is less than INR 50 lacs) and 10 years where the monetary threshold is breached (subject to further grandfathering to 6 years for pre-amendment years).

The Article provides views on the question of applicability of limitation period as prescribed under amended Sec. 149 of the Act after the Supreme Court’s recent judgement on issuance of notices.

The Unanswered Question of Limitation– A contentious issue post Supreme Court ruling on reassessment controversy – Aureus Law Partners

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