Reassessment Notice Held Valid Because SCN Period Is Excluded from Limitation: ITAT Mumbai

Albert Joseph Rozario Vs ITO (ITAT Mumbai) The appeal before the Income Tax Appellate Tribunal, Mumbai concerned the validity of reassessment proceedings for Assessment Year 2018–19 and the consequent additions made on a protective basis. The Assessing Officer (AO) initiated proceedings under section 148A after information indicated that the assessee had purchased immovable properties worth ₹8.31 crore and had not filed a return of income. A show-cause notice under section 148A(b) dated 23 March 2022 was served, granting time up to 18 April 2022 to respond. As no reply was filed, the AO pa...