Section 148 Notice Invalid Since Issued After Surviving 23-Day Limitation Period

K & S Fincon Pvt. Ltd. Vs ITO (ITAT Delhi)

Whether the notice issued under Section 148 dated 20.07.2022 for AY 2013–14 is barred by limitation,( Amended 148 read with TOLA)

I. Background and Chronology

The appeal concerned AY 2013–14. The material dates are

Particulars	Date
Return filed	26.10.2013
Assessment u/s 143(3)	14.03.2016
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