Time-Barred Section 148 Notice Nullifies 263 Revision: ITAT Mumbai Quashes PCIT’s Order

Jignesh Mahesh Gohel Vs DCIT (ITAT Mumbai) Time-Barred 148 Notice Dooms 263 Revision – ITAT Mumbai Quashes PCIT’s Order; Non-Est Reassessment Cannot Be Revised Assessee had originally filed return declaring income of Rs. 5.01 lakh. On receipt of information from the Investigation Wing that the Assessee had allegedly paid ‘On Money’ of Rs. 81.12 lakh to M/s Runwal Group for purchase of a shop, AO reopened the assessment by issuing notice u/s 148 & finally passed reassessment order u/s 147 r.w.s. 144B on 30.03.2023 accepting the returned income. PCIT later invoked Explanation 2 to s...