Reassessment notice was invalid if it was issued beyond the calculated “surviving time” or “last date” time limit

Prolife Industries Limited Vs ITO (Gujarat High Court) Conclusion: Since the last date, or the “surviving time,” for issuing a valid notice under Section 148 for this specific case was June 17, 2022 and the actual notice was issued on August 24, 2022, it was clearly barred by limitation. Held: AO issued a notice under section 148 for AY 2014–15, invoking the extended limitation period under TOLA, 2020. In light of the Supreme Court’s ruling in Union of India v. Ashish Agarwal (2022) 444 ITR 1 (SC), such notices issued between 01.04.2021 and 30.06.2021 were deemed as notices under secti...