Reopening Invalidated – Less Than 7 Days’ Notice Violates section 148A(b)

Sulabha Ramesh Ganorkar Vs ITO (ITAT Nagpur) Assessee filed appeal against order of CIT(A) which had upheld reassessment framed u/s 147 r.w.s. 144B making additions of Rs.11,03,500/- as unexplained u/s 69A & Rs.56,666/- as unexplained accrued interest on FDR. Before Tribunal, Assessee challenged validity of reopening on the ground that notice u/s 148A(b) dt 23.03.2022 provided only 6 days to respond (till 29.03.2022) instead of the mandatory 7 clear days, thereby vitiating entire proceedings. Reliance was placed on Bombay HC in Samadha Corporation Vs ITO (WP 2154/2022), Mukesh J. Ruparel V...