Notice u/s 148 Issued 20 Days Late – ITAT Applies Rajeev Bansal & Gujarat HC, Quashes Reopening as Time-Barred

Na Roto Machine & Moulds India Vs ACIT (ITAT Ahmedabad) Notice u/s 148 Issued 20 Days Late – ITAT Applies Rajeev Bansal & Gujarat HC, Quashes Reopening as Time-Barred Assessee filed return for AY 2017-18. Later, reassessment was initiated based on survey material found in the case of a third party, alleging Assessee received Rs.6,00,000/- in cash for sale of machinery. Original notice u/s 148 was issued on 30.06.2021 under old regime, which, pursuant to Supreme Court judgment in Ashish Agarwal, was treated as deemed notice u/s 148A(b) of the new regime. Assessee was supplied material...