Section 148 Notice Invalid as It Was Served After Limitation Period: ITAT Mumbai

Pradeep Shyamlal Sayani Vs ITO (ITAT Mumbai) The ITAT Mumbai allowed the assessee’s appeal and quashed reassessment proceedings after holding that a notice under Section 148 cannot be treated as issued within limitation merely because it bore an earlier date when it was actually signed and served later. The assessee had filed a return declaring total income of ₹5,82,400 for AY 2017-18. The case was reopened based on information that deposits of ₹1.46 crore had been made in eight bank accounts maintained with ICICI Bank and Syndicate Bank. The Assessing Officer (AO) issued a notice under ...