Reassessment After 31-03-2024 Time-Barred; First Proviso to Sec. 149(1) Prevails Over 148A – Proceedings Quashed by ITAT Bangalore

Neeta Bhambhani Vs DCIT (ITAT Bangalore) Reassessment Notice Issued After 31-03-2024 Held Time-Barred – First Proviso to Sec.149(1) Overrides 148A Proceedings – Entire Reassessment Quashed – ITAT Bangalore In IT(IT)A No.3124/Bang/2025, AY 2017-18, the assessee, a non-resident individual, challenged reassessment proceedings initiated u/s 147 based on information of cash deposits and interest income. The Tribunal first admitted additional legal grounds relating to limitation, holding that pure questions of law affecting jurisdiction can be raised at any stage. The core issue was whether no...