Reassessment Quashed as Time-Barred – Fresh Notice U/s 148 Issued Beyond Surviving Period After Ashish Agarwal Judgment

Pakarahalli Narayanappa Srinivasgowda Vs ITO (ITAT Bangalore) The assessee was alleged to have received ₹22.13 crore in connection with a property transaction where he was a confirming party. Based on this information, the AO issued a notice u/s 148 on 29-06-2021 under the old reassessment regime. Following the Supreme Court decision in Union of India v. Ashish Agarwal, such notices were treated as show-cause notices under the new regime and the AO subsequently issued notice u/s 148A(b) on 20-05-2022, to which the assessee replied on 05-06-2022. Thereafter, the AO passed an order u/s 148A(d)...