Late Section 148 Notice Leads to Complete Reassessment Failure

Kumar Matunga Project Vs ITO (ITAT Pune) Reassessment for AY 2015-16 Time-Barred Post-Ashish Agarwal: ITAT Pune Quashes Section 148 Notice The Pune Bench of the ITAT allowed the assessee-firm’s appeal for AY 2015-16 and quashed the reassessment proceedings, holding that the notice issued under section 148 dated 23.07.2022 was barred by limitation and therefore bad in law. The Tribunal noted that the original notice under section 148 was issued on 16.04.2021 and, pursuant to Union of India v. Ashish Agarwal (SC), the AO issued a section 148A(b) notice on 24.05.2022, followed by the order unde...