Notice u/s 148 Issued Beyond ‘Surviving Time’ Quashed: ITAT Follows Rajeev Bansal (SC)

Smt. Sobha Rani Vs ITO (ITAT Delhi) Assessee filed appeal against order of NFAC, confirming reassessment u/s 147 r.w.s. 144B for AY 2017-18. The reassessment added ₹17.62 lakh as unexplained income, raising total assessed income to ₹19.18 lakh. Before Tribunal, Assessee challenged reassessment on the sole legal ground that the notice issued u/s 148 on 26.07.2022 was barred by limitation. The original notice under the Taxation & Other Laws (Relaxation & Amendment of Certain Provisions) Act, 2020 (TOLA) was issued on 29.06.2021. The escaped income being below ₹50 lakh, the case fel...