ITAT Kolkata Quashes Reopening as Time-Barred – Notice u/s 148 Issued Beyond Limitation

Sushma Mimani Vs ITO (ITAT Kolkata) Kolkata Tribunal held that reassessment initiated u/s 147 r.w.s. 148 was barred by limitation as the notice u/s 148 was issued after expiry of statutory time limit. Assessee filed return for AY 2013-14 declaring income of ₹6,10,297/-. Original reassessment notice u/s 148 was issued on 30.06.2021 (last permissible date under extended limitation by TOLA).  Pursuant to SC ruling in UOI vs. Ashish Agarwal (2022), such notices issued between 01.04.2021 & 04.05.2022 were deemed as notices u/s 148A(b). AO issued notice u/s 148A(b) on 25.05.2022 granting 14...