Gujarat HC Quashes Time-Barred Section 148 Notice Post-TOLA

Dahyabhai Narayandas Patel Vs ITO (Gujarat High Court) The Gujarat High Court, in Dahyabhai Narayandas Patel vs ITO, considered the validity of a notice issued under section 148 of the Income Tax Act, 1961 for Assessment Year 2017-2018. The petitioner challenged the notice dated 28.08.2022 as being time-barred. The notice had been issued during the extended period allowed under the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA). The Court examined the implications of the Supreme Court rulings in Union of India v. Ashish Agarwal (2022) and Union of India v. R...