ITAT Hyderabad Quashes Reassessment Due to Time-Barred Section 148 Notice

Ikramudin Mohammed Vs ITO (ITAT Hyderabad) Summary: The ITAT Hyderabad quashed reassessment proceedings on the ground that the notice issued under Section 148 was barred by limitation and based on incorrect facts. The Assessing Officer issued the notice on 07.04.2022 for AY 2015–16, which was beyond the permissible time limits under Section 149. The Tribunal observed that the actual alleged escaped income was below ₹50 lakh, making the applicable limitation period three years, which had already expired. It further noted that the AO had artificially inflated the escapement amount by duplic...