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Section 148 Notice Issued After Limitation Period Declared Invalid
Case Law Details
- Case Name
- Anand Swaroop Vs ITO (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All ITAT, ITAT Delhi
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Anand Swaroop Vs ITO (ITAT Delhi)
AY 2015-16: Fresh s.148 notice after 01-07-2022 is time-barred
Delhi ITAT quashed reassessment proceedings by holding that the notice issued u/s 148 on 14-07-2022 was barred by limitation. The Tribunal noted that the original notice dated 30-06-2021 issued under the unamended law was treated as a show-cause notice pursuant to Ashish Agarwal, & the fresh notice could be issued only within the “surviving period” as clarified by the Supreme Court in Rajeev Bansal. For AY 2015-16, the last permissible date to issue a fresh notice was...





