Notice for reassessment u/s. 148 issued beyond surviving time limit is time-barred: Gujarat HC

Sheetal Dhamreshbhai Patel Vs ITO (Gujarat High Court) Gujarat High Court held that reopening of assessment by issuance of notice under section 148 issued beyond the surviving time limit as prescribed under Income Tax Act read with TOLA is barred by limitation. Accordingly, notice is quashed and writ petition allowed. Facts- By this petition under Article 226/227 of the Constitution of India, the petitioner has challenged assessment order dated 29.07.2022 passed by Respondent No.1 under Section 148A(d) of the Income Tax Act, 1961 which inter alia propose to re-open the assessment. Conclusion- ...