Reassessment based on direction of CIT(A) post period prescribed u/s. 149 cannot be sustained

Shubh Buildcon Vs ITO (Gujarat High Court) Gujarat High Court held that reopening of assessment based on direction of CIT(A) cannot be sustained since the period of limitation prescribed under section 149(1) of the Income Tax Act has expired. Accordingly, reassessment notice u/s. 148 quashed and petition is allowed. Facts- The petitioner a Partnership Firm filed the return of income on 20.03.2012 along with detailed computation of income for A.Y. 2011-12 which were processed u/s. 143(1) of the Act. The petitioner thereafter on 29.11.2014 filed the return of income for A.Y. 2014-15 declaring t...