ITAT Quashes Assessment Without Fresh notice u/s 148

Mahalaxmi Gramin Bigarsheti Sahakari Patsanstha Vs ITO (ITAT Pune) Summary The ITAT Pune allowed the appeal of the assessee and quashed the assessment order for AY 2018-19. The Tribunal held that when an AO reopens an assessment for specific reasons under Section 148 but later accepts the assessee’s explanation and then seeks to make additions on entirely different grounds, a fresh notice under Section 148 is mandatory. The case reinforces the principle that tax authorities cannot shift assessment grounds mid-stream without following proper legal procedures. Facts of the Case The assesse...