Section 148 Notices Beyond 3 Years Require Proof of Concealed Income Over ₹50 Lakh

ITO Vs Nishan Govindbhai Thakkar (ITAT Ahmedabad)

The Income Tax Appellate Tribunal (ITAT), Ahmedabad, has dismissed the Revenue’s appeal against the order of the Commissioner of Income Tax (Appeals) [CIT(A)], which had quashed the reassessment notice issued under Section 148 of the Income Tax Act. The notice was issued by the Assessing Officer (AO) beyond the prescribed time limit under Section 149(1)(a) for Assessment Year (AY) 2017-18. The case involved allegations that the assessee, Nishan Govindbhai Thakkar, had booked fictitious profits from trading shares of Shivansh F

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