Reassessment Notice Issued Beyond Surviving Time Held Invalid: Gujarat HC

Ashitkumar Satishchandra Patel Vs ITO (Gujarat High Court) The Gujarat High Court adjudicated a writ petition filed under Article 226 of the Constitution challenging the validity of a notice issued under Section 148 of the Income Tax Act, 1961, for the Assessment Year 2016–17. The petitioner contended that the notice dated 30 August 2022 was invalid and time-barred. The case involved the interplay between the reassessment provisions under Section 148, the transitional framework introduced by the Finance Act, 2021 (which inserted Section 148A effective from 1 April 2021), and the time extensi...