Reassessment notice u/s. 148 under TOLA quashed as time-barred: Gujarat HC

Tyrone Patrick Lemos Vs DCIT (Gujarat High Court)

Gujarat High Court held that reassessment notice issued u/s. 148 of the Income Tax Act under the provisions of the Taxation and Other Laws [Relaxation and Amendment of Certain Provisions] Act, 2020 [TOLA] liable to be quashed as issued beyond surviving period and hence are time-barred.

Facts- The petitioner filed return of income for the Assessment Year 2013-14 on 28.04.2016. A notice dated 30.6.2021 was issued u/s. 148 of the Act under the provisions of the Taxation and Other Laws (Relaxation and Amendment o

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