Section 148 Notice Invalid Because Dispatch Date, Not Signature Date, Determines Issuance

Chandanam Sangaih & Son Vs ITO (ITAT Visakhapatnam) Section 148 Notice Dispatched After 01.04.2021 — Reassessment Quashed for Non-Compliance with Section 148A The Visakhapatnam Bench of the ITAT quashed the reassessment for AY 2017–18 holding that the notice under Section 148, though dated 29.03.2021, was issued only on 08.04.2021, being the date of dispatch through speed post, and therefore governed by the post-Finance Act, 2021 reassessment regime. Relying on Kanubhai M. Patel (HUF) v. Hiren Bhatt, the Tribunal reiterated that the date of issuance is the date of handing over to posta...