Reassessment Quashed for Being Time-Barred: ITAT Holds 148 Notice Beyond Six-Year Limit

Bhargav Ram Munagapati Vs ITO (ITAT Visakhapatnam) AY 2015-16 Reassessment Quashed—148 Notice Dated 03.04.2022 Held Time-Barred Beyond Six-Year Limit under Section 149(1)(b) The Tribunal held that the reassessment proceedings initiated for AY 2015-16 are without jurisdiction, since the notice under section 148 dated 03.04.2022 was issued beyond the prescribed period of six years as per the first proviso to section 149(1)(b). Following the binding ratio of the Hon’ble Supreme Court in Union of India v. Rajeev Bansal and Deepak Steel and Power Ltd., it was concluded that for AY 2015-16, all ...