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Limitation Runs From Statutory Reply Period, Not Actual Reply Date
Case Law Details
- Case Name
- Waves Tradeline Private Limited Vs ITO (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All ITAT, ITAT Ahmedabad
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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...
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