Reopening notice u/s. 148 issued after surviving period is time-barred and hence set aside

Hitesh Ramniklal Shah Vs ACIT (Bombay High Court) Bombay High Court held that reopening of assessment by issuance of notice under section 148 of the Income Tax Act issued much after the surviving period is barred by limitation. Accordingly, notices are set aside and petition is allowed. Facts- By this Petition, the Petitioner challenges a notice dated 27 July 2022 issued under Section 148 of the Income-tax Act, 1961, the subsequent notices dated 9 October 2025 and 14 October 2025 issued under Section 142(1) of the Act, and the show cause notice dated 18 October 2025 issued by Respondent No.1,...