Notice Invalid as Limitation Exhausted Despite Section 148A Process

Abdul Salam Mohamed Yasin Vs DCIT (ITAT Mumbai) Reassessment Time-Barred Under Rajeev Bansal; Sanction by PCIT Invalid: ITAT Mumbai Quashes Notice u/s 148 for AY 2017-18 The Mumbai ITAT (“A” Bench) allowed the appeal of the assessee for AY 2017-18 and annulled the reassessment proceedings on purely jurisdictional grounds, holding that the notice issued under section 148 was barred by limitation and further vitiated by invalid sanction under section 151(ii). The Tribunal examined the complete chronology in light of the Supreme Court decisions in Ashish Agarwal and Union of India v. Rajeev B...