Notice Under Section 148 Quashed for Exceeding Limitation Computed Under TOLA

Vinodkumar Rughnathbhai Koringa Vs ITO (Gujarat High Court)

The petition was filed under Article 226 of the Constitution challenging the notice dated 31.07.2022 issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2017-18, on the ground that it was invalid and time-barred.

The Assessing Officer had originally issued a notice dated 11.06.2021 under Section 148 during the extended time period provided under the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA). In view of the decision of the Supreme Court in Union of Indi

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