Section 148 Notice Issued Beyond First Proviso to Section 149 Time Limit Quashed: ITAT Mumbai

Mohamedali Shabanali Badami Vs ITO (ITAT Mumbai) The appeal challenged the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), which had upheld an assessment framed under Sections 144 read with 147 of the Income-tax Act, 1961 for Assessment Year (AY) 2015-16. The principal issue before the Tribunal was whether the notice issued under Section 148 on 19.04.2022 was barred by limitation under the first proviso to Section 149 and whether the consequential reassessment proceedings and assessment order were invalid. The assessee contended that the CIT(A) failed...