Notice issued u/s. 148 after period of six years for AY 2015-16 is barred by limitation: ITAT Mumbai

ACIT Vs Manish Financial (ITAT Mumbai) ITAT Mumbai held that validity of notice issued under section 148 of the Income Tax Act for AY 2015-16 is six year which expires on 31.03.2022. Accordingly, notice issued on 29.07.2022 u/s. 148 is barred by limitation. Facts- AO reopened the assessment by issuing notice under section 148 of the Act dated 29.06.2021 for the reason that the assessee has derived fictitious loss in the trading of equity derivatives and the assessee is a beneficiary of bogus capital gains. The said notice become deemed to be a notice issued under section 148A(b) of the Act, as...