Reassessment under section 148: Reasons to believe

The document wherein the reason to believe has been recorded as well the approval of the JCIT/CIT has been received , should be obtained to analyse the reason of notice u/s 148 . The AO is not obliged to send the copy of the satisfaction note along with the notice and in case you require you can request that either directly or through the AR .

The limitation works on the issue of notice and not on the serve of the notice . Further once notice has been issued U/s 148 . The limitation is not linked with the issue of satisfaction note .

if the case is in Delhi the undersigned can offer professional service to you . You can contact u on -prakash@psc.co.in

Dear Ashish,

There is no time limit for supplying the reason to believe. Time limit is for issuing notice under section 148. If he has issued the notice within time limit then the notice is valid subject to any other discrepancies in the notice like - reason to believe is not a good reason etc.

Thanks and Regards,

CA Abhishek Dugar

I Agree with Mr Prakash Sinha

Dear Sir

The Time limit of 6 years is for servcing of the Notice u/s. 148 and not for giving the reasons for the reassessment. The request and provision of reasons for reassessment are all part of the post issue of notice activities.

In my opinion, if the Assessing officer has served the notice before 31st of March, then the notice is valid and the other procedures (giving the reasons for selection for reassessement) does not come under the above time limit.

No Sir,

It appears that you have interpreted it wrongly. The Time limit of 6 years is for servcing of the Notice u/s. 148 and not for giving the reasons for the reassessment. So the AO is not time barred in his act, and can legally do so.

Trust this clarifies your query.

Feel free to get back/ call back for any further clarifications.

Thanking You.

Regards,

Rohit R Sharma

BCOM, ACA, LLB - GEN, CERT. FAFP

I think the same is being answered by my other professional colleagues.

Then also I submit that your case is opened till 31-03-2017. You need to just check whether the AO has sent you another notice U/s. 143(2) of the It Act for scrutiny purpose.