Section 148 Notice Issued After Limitation Period Declared Invalid

Anand Swaroop Vs ITO (ITAT Delhi) AY 2015-16: Fresh s.148 notice after 01-07-2022 is time-barred Delhi ITAT   quashed reassessment proceedings by holding that the notice issued u/s 148 on 14-07-2022 was barred by limitation. The Tribunal noted that the original notice dated 30-06-2021 issued under the unamended law was treated as a show-cause notice pursuant to Ashish Agarwal, &  the fresh notice could be issued only within the “surviving period” as clarified by the Supreme Court in Rajeev Bansal. For AY 2015-16, the last permissible date to issue a fresh notice was 01-07-2022, &...