Section 148 Notice Time-Barred, Reassessment Void Ab Initio: ITAT Delhi

ACIT Vs Prem Chand Pravesh Kumar (ITAT Delhi)

Late 148 Notice Fatal -: ITAT Delhi Holds Notice u/s 148 Time-Barred-Reassessment Quashed

AO had originally issued notice u/s 148 on 30.06.2021 under the old law (pre-Finance Act, 2021). Pursuant to SC ruling in Ashish Agarwal, a fresh process was initiated u/s 148A, with show-cause issued on 26.05.2022, reply filed on 09.06.2022 & order u/s 148A(d) passed on 26.07.2022. A fresh notice u/s 148 was issued on 26.07.2022, leading to reassessment u/s 147 r.w.s. 144B on 27.05.2023. NFAC upheld the reassessment, against which Reven

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