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Validity of 148 issued on 20.07.2022

Ajay Ajmera

Dear all

Recently on 03.10.2024, Honble Supreme court has delivered its judgement on validity of 148 Notices issued between 01.04.2021 to 30.06.2021. please advise whether 148 for A.Y. 2013-14 issued on 20.07.2022 is valid or not, having regards to the following facts:-

1. Original 148:28.06.2021

2. 148A(1)(d); 26.05.2022

3. Time allowed to response: 09.06.2022

4.Date of Assessee Submissions: 03.06.2022

5. Date of new 148: 20.07.2022

Time limitation on section 148 notices: reissued reassessment notices may be time-barred absent fresh material. Where an earlier section 148 notice and a subsequent section 148A(1)(d) notice were issued and the assessee responded within the prescribed window, a later reissued section 148 directed to the same assessment year and same factual matrix is procedurally time-barred unless fresh, independent material justifies reopening the assessment. (AI Summary)
Income Tax
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DR.MARIAPPAN GOVINDARAJAN on Nov 15, 2024

In my opinion it is time barred

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