ITAT Rajkot Quashes Reassessment as Section 148 Notice Issued Beyond Surviving Time

Shreedhar Construction Vs ITO (ITAT Rajkot) The assessee filed an appeal before the Tribunal against the order of the Commissioner of Income Tax (Appeals), NFAC, Delhi dated 25.06.2025, arising from reassessment proceedings under Sections 147 r.w.s. 144 of the Income Tax Act, 1961 for Assessment Year (AY) 2014-15. The assessee raised multiple grounds, primarily challenging the validity of notice issued under Section 148. It was contended that the notice was beyond the “surviving period” as laid down by the Supreme Court in Union of India v. Rajeev Bansal (167 taxmann.com 70). The assessee ...