IT Reassessment Notice Beyond TOLA’s Limitation Period Invalid: ITAT Mumbai

CLE Private Limited Vs DCIT (ITAT Mumbai) Income Tax Appellate Tribunal (ITAT) Mumbai addressed the issue of reassessment initiated against CLE Private Limited, focusing primarily on the validity of the reassessment notice issued under Section 148 of the Income Tax Act. The core contention was whether the notice was issued within the permissible time limit, considering the provisions of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). The original return of income was filed on September 30, 2015, and the scrutiny assessment was completed on Decembe...