Time-Barred Notices Under Section 148 Lead to Quashing of Assessments

ITO Vs Ilesh Infracap Private Limited (ITAT Ahmedabad) Limitation Fatality -TOLA Clock Runs Out- Surviving Time Kills Reopening – ITAT Ahmedabad Strikes Down Time-Barred 148 Notices Assessee filed ROI for AY 2014-15 declaring Nil income. AO reopened the case based on credit entries of ₹4,34,67,000 in the IDBI Bank account & completed reassessment u/s 147 r.w.s 144B treating the entire amount as unexplained. CIT(A) deleted the addition. Before Tribunal, Assessee supported CIT(A)’s order through a Rule 27 application, challenging the very validity of the 148 notice. The initial not...