Reopening Dies Twice: ITAT Hyderabad Quashes 148 Notice for Limitation Wrong Approval

Brijesh Chandwani Vs DCIT (ITAT Hyderabad) Hyderabad Tribunal examined the validity of reassessment proceedings initiated by AO through notice u/s 148 dated 29.07.2022. For AY 2016-17, original scrutiny u/s 143(3) was completed on 19.12.2018. AO issued an old-regime 148 notice on 30.06.2021—the last day of the TOLA-extended period. By virtue of Ashish Agarwal (SC), this notice was deemed to be 148A(b). AO then issued 148A(b) SCN on 25.05.2022, passed 148A(d) order on 29.07.2022 & simultaneously issued final 148 notice on 29.07.2022. Tribunal, applying Union of India vs Rajeev Bansal (SC)...