Reassessment Notice Quashed Because It Was Issued Beyond Limitation: Bombay HC

Guru Udyog Private Limited Vs ITO (Bombay High Court) Limitation for issuance of notice u/s 148 – Surviving period under TOLA – Scope of new reassessment regime- Where the original notice under the old Section 148 was issued on 29-06-2021, the limitation under TOLA expired on 30-06-2021, leaving only 2 days of surviving limitation. Whether a notice issued under Section 148 on 30.07.2022 for AY 2014-15 was barred by limitation, considering the “surviving limitation period” under TOLA and the mechanism laid down by the Supreme Court in: Union of India v. Ashish Agarwal and Union of Indi...