“Section 149(1)(h)”

ANIL SINGH,KOLKATA vs. I.T.O., WARD - 49(1),, KOLKATA

In the result, appeal of the assessee is allowed

Bench: Shri George Mathanआयकर अपील सं/Ita No.531/Kol/2025 (नििाारण वर्ा / Assessment Year :2017-2018) Anil Singh Vs Ito Ward-49(1), Kolkata/Nfac 4, Railway Gate, Lalkuthi, Kamarhati, Kolkata Pan No. : Bflps 0954 J (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Soumitra Choudhury, Advocate राजस्व की ओर से /Revenue By : Smt. Sima Das Biswas, Jcit-Sr.Dr सुनवाई की तारीख / Date Of Hearing : 16/07/2025 घोषणा की तारीख/Date Of Pronouncement : 16/07/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 29.07.2024 For The Assessment Year 2017-2018. 2. Shri Soumitra Choudhury, Ld.Ar Appeared On Behalf Of The Assessee & Smt. Sima Das Biswas, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. The Appeal Of The Assessee Is Barred By 168 Days. In This Regard, The Assessee Has Filed An Application For Condonation Of Delay Stating Therein Sufficient Reasons For Delay, Which Are Plausible & Not Found To Be False. Ld. Sr.Dr Also Did Not Raise Any Serious Objection To Condone The Delay. Accordingly, Delay Of 168 Days In Filing The Present Appeal By The Assessee Is Condoned & The Appeal Is Admitted For Hearing. 4. It Was Submitted By The Ld. Ar That This Is A Case Of Reopening & Issuance Of Notice U/S.148 Of The Act. It Was The Submission That The Notice

expired at the time of issuance of the notice. This also ensures that the new time limit of ten years prescribed under Section 149(1)(h) of the new regime applies prospectively. For example, for the assessment year 2012-2013, the ten year period would have expired on 31 March