ITAT Ahmedabad: Reassessment Annulled as Notice u/s 148 Issued Beyond Surviving Limitation Period — Invalid under Rajeev Bansal & TOLA Framework

Manubhai Keshavlal &Co. Vs ITO (ITAT Ahmedabad) ITAT Ahmedabad: Reassessment Annulled as Notice u/s 148 Issued Beyond Surviving Limitation Period — Invalid under Rajeev Bansal & TOLA Framework Assessee, a partnership firm engaged in trading at Visnagar, filed its return for AY 2016-17. Later, AO reopened the assessment u/s 147, issuing a notice u/s 148, & added ₹3,71,367/- treating it as the value of a tour package received in the course of business, taxable as a benefit u/s 28(iv). The firm challenged not just the addition but the very validity of the reassessment, contending ...