Whether reassessment proceedings initiated for AY 2015-16 relying on TOLA and Instruction issued by CBDT is bared by limitation?

Dilip Bhikhalal Desai Vs DCIT (Calcutta High Court)

Justice Shekhar B Saraf in this order was dealing with challenge to the order u/s 148A(d) and Notice u/s 148 dated 29th July,2022 which was passed by the AO for the AY 2015-16 admittedly relying on the Instruction No 01/2022 dated 11th May, 2022 and Appellant argued that the order as well as notice w

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