Notice issued within time but Served After Limitation Period Voids Reopening: ITAT Kolkata

Festino Vincom Limited Vs ITO (ITAT Kolkata) Notice u/s 148 issued on 31.03.2018 but served on 11.04.2018; service beyond 6-year limit u/s 149(1)(b) makes reopening time-barred & void ab initio-ITAT Kolkata quashes reassessment Assessee filed its return on 29.09.2011 declaring income of ₹4,850, which was processed u/s 143(1). Later, AO reopened the case u/s 147 based on Investigation Wing information that ₹16.46 crore had allegedly been routed through layering of companies to Assessee. A notice u/s 148 was issued on 31.03.2018, &  reassessment was completed u/s 144/147 making addi...