Hyderabad ITAT Quashes AY 2015-16 Reopening – Notice u/s 148 Issued After 6 Years Held Time-Barred Despite ₹50 Lakh Escape Claim

Afreed Mohammad Vs ACIT (ITAT Hyderabad) Hyderabad ITAT Quashes AY 2015-16 Reopening – Notice u/s 148 Issued After 6 Years Held Time-Barred Despite ₹50 Lakh Escape Claim The Hyderabad ITAT quashed the reassessment proceedings for AY 2015-16 holding that the notice issued u/s 148 on 06.04.2022 was barred by limitation, since it was issued beyond six years from the end of the relevant assessment year. The Tribunal held that for assessment years beginning on or before 01.04.2021, the protection under the first proviso to section 149 applies and the amended 10-year reopening window cannot revi...