Authority: High Court of Judicature at Madras
Order Date: 16 July 2026
Case Overview
- Parties: Appellant – Shanmugha Arts, Science Technology and Research Academy, represented by Trustee and Vice‑Chancellor S. Vaidhyasubramaniam; Respondents – ACIT (Exemptions), Assessment Unit Income‑Tax Department, Commissioner of Income Tax Audit, Principal Chief Commissioner of Income Tax.
- Nature of Proceeding: Appeal under Clause 15 of the Letters Patent against the order dated 3 June 2026 (W.P.No.29752 of 2023) which had dismissed the appellant’s challenge to reassessment notices.
- Background: Reassessment notices for Assessment Year 2015‑2016 were issued on 12 April 2021 (first notice) and 31 March 2022 (Section 148A(b) notice), leading to an order on 2 May 2022. The appellant contended that these actions were barred by limitation.
- Legal Reference: The court considered the Supreme Court judgment Union of India v. Rajeev Bansal (2024 SCC Online SC 2693), specifically paragraph 19(f), which holds that for AY 2015‑2016 any notice issued on or after 1 April 2021 must be dropped as it falls outside the period prescribed under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA).
Final Outcome
- The appeal is allowed; the impugned order dated 3 June 2026 is set aside.
- The reassessment notices dated 12 April 2021 and 31 March 2022, together with the order dated 2 May 2022, are quashed.
- No order as to costs.
- The connected interim application stands closed.
Topics: Tax Limitation, Judicial Precedent