Reassessment Time-Barred Despite TOLA SC Relaxation – Notice Held Void

ACIT Vs Vihar Infrastructure Private Limited (ITAT Mumbai) Reassessment Time-Barred Despite TOLA SC Relaxation – Notice Held Void Mumbai ITAT upheld the quashing of reassessment proceedings, holding that the notice u/s 148 issued on 27.07.2022 was time-barred, even after considering TOLA extensions and Supreme Court rulings in Ashish Agarwal and Rajeev Bansal. The Tribunal explained that: Old notices issued between 01.04.2021–30.06.2021 are deemed as 148A(b) notices under Ashish Agarwal As per Rajeev Bansal, “surviving time” must be computed from the original notice date till 30.06.20...