Dear Experts,
My client was received notice from the Income tax Officer after expiry of 4 years(recd on 03.04.2018), but it was dispatched by the authority on 27.03.2018 relates to A.Y. 2011-12 and subsequently the client had filed return and submitted the same before the Income tax Officer. The ITO has been rejected the return and passed the Order u/s 143(3) rws 147 of IT Act. Further they went appeal before CIT(A) there also they have lost and later they filed appeal before ITAT which is pending due to COVID-19.
In the above situation, can i invoke sec 148 with limitation point before ITAT?
Can anyone suggest me for the next course of action.
Taxpayer Challenges Rejection of Assessment Year 2011-12 Under IT Act Sections 143(3), 147; Considers Section 148 for Limitation Issues An individual sought advice regarding an Income Tax notice received after four years, related to the assessment year 2011-12. The notice was dispatched before the deadline, but the return filed was rejected under section 143(3) read with section 147 of the IT Act. Appeals to the Commissioner of Income Tax (Appeals) were unsuccessful, and the case is now pending before the Income Tax Appellate Tribunal (ITAT) due to COVID-19 delays. The individual inquired about invoking section 148 regarding the limitation period. A respondent affirmed the possibility, while another raised concerns about section 292BB and the sustainability of limitation objections. (AI Summary)
TaxTMI 
TaxTMI 
TaxTMI 
