Reopening of assessment beyond the period of limitation was...

Reopening of assessment beyond the period of limitation was challenged, but the notice u/s 148 was issued within the six-year time limit on 28.03.2018 and served on 02.04.2018, complying with Section 149's requirement for issuing the notice. The legality of the assessment order was questioned due to the dismissal of the financial creditor's petition under the Insolvency & Bankruptcy Code, 2016, but the Assessing Officer had no information about the NCLT order at the time of passing the reassessment order. The addition based on audited financial statements submitted to Punjab National Bank was remitted to the Assessing Officer for de novo consideration and fresh decision, with the assessee directed to file necessary documents for proper adjudication. The appeal was partly allowed for statistical purposes.

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