S. 147 reopening reasons need not be supplied within limitation period

A. G. Holdings Pvt. Ltd vs. ITO (Delhi High Court)

For AY 2004-05, the AO issued a notice u/s 148 on 15.3.2011. The recorded reasons were supplied to the assessee on 30.8.2011 (after the expiry of the limitation period of 6 years). The assessee, relying on Haryana Acrylic vs. CIT 308 ITR 38 (Del), challenged the reopening inter alia on the ground that as the recorded reasons were supplied after the expiry of the limitation period, the reassessment proceedings were invalid. HELD dismissing the petition: