Reassessment Quashed – Notice U/s 148 Held Time-Barred & Ante-Dated

Gurusamy Suseela Vs ITO (ITAT Chennai) The assessee challenged the validity of reassessment for AY 2010-11 on the ground that the notice issued u/s 148 was beyond the statutory time limit. Under section 149, the last date for issuing notice was 31.03.2017 (six years from the end of the relevant assessment year). Although the notice bore the date 31.03.2017, the assessee produced evidence showing that it was actually dispatched later, including the speed-post envelope showing dispatch on 03.04.2017. The assessee therefore argued that the notice was ante-dated and issued after the limitation per...