Limitation Runs From Statutory Reply Period, Not Actual Reply Date

Waves Tradeline Private Limited Vs ITO (ITAT Ahmedabad) Reopening Collapses on Limitation: ITAT Ahmedabad Quashes Reassessments for AYs 2015-16 to 2017-18 as Time-Barred ITAT Ahmedabad “D” Bench, in Waves Tradeline Pvt. Ltd. vs ITO (ITA Nos. 1228, 1229 & 1230/Ahd/2025, AYs 2015-16, 2016-17 & 2017-18; order dated 24.12.2025), has quashed reassessment proceedings in their entirety by holding that all notices issued u/s 148 were barred by limitation and hence without jurisdiction. For AY 2015-16, Tribunal held that the original notice u/s 148 dated 07.06.2021, though issued under TOLA...