Reassessment Notice Issued on 31.03.2021 but Served on 01.04.2021 Quashed by Gujarat HC

Saumil Avinash Baheti Vs ITO (Gujarat High Court) Gujarat High Court, on July 25, 2025, quashed a reassessment notice issued under Section 148 of the Income Tax Act, 1961, to Saumil Avinash Baheti for Assessment Year 2017-18. The court’s decision hinged on the tax department’s failure to issue a mandatory fresh notice under Section 148A(b) following the directives of the Supreme Court in the case of Union of India and others vs. Shri Ashish Agarwal and others (444 ITR pg 1 SC). The petitioner argued that while the impugned notice was dated March 31, 2021, it was served via email on...