TOLA Can’t Extend Section 148 Timeline: Rajkot ITAT Quashes Reopening

Vallabhbhai Bhagvanjibhai Kathiriya Vs ITO (ITAT Rajkot) Foundation Removed, Structure Falls: Assessment & Penalties Nullified as 148 Notice Held Invalid- Rajkot ITAT Quashes Reopening for AY 2015-16: TOLA Cannot Extend Time for 148 Notice These ten appeals by Assessee were heard together, involving quantum additions u/s 69A, profit-rate estimations, & penalties u/s 271A, 271(1)(c) & 271F arising from reassessment proceedings of multiple years. Lead case was AY 2015-16 (ITA 515/RJT/2025) in which Assessee, a non-filer trading in brass items on commission basis, had cash credits of ...