Entire 148A and 147 Proceedings Set Aside for Being Time-Barred

Satva Merchandize Pvt. Ltd. Vs ITO (ITAT Ahmedabad)

Reopening for AY 2015-16 Based on Notice Issued After 01.04.2021 Held Void; Entire Proceedings Under 148A & 147 Quashed

In this appeal filed by Satva Merchandize Pvt. Ltd. against the reassessment framed u/s 147 r.w.s. 144B, ITAT Ahmedabad examined the validity of notices issued under the new reassessment regime for AY 2015-16. The Assessing Officer had initially issued a notice u/s 148 on 20.04.2021 alleging accommodation-entry purchases of

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