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HC held that despite considering three block periods of limitation exclusion as per SC precedents, the re-assessment notice dated 23 July 2022 exceeded statutory limitation. The court specifically noted that even after adding 14 days for assessee's response to Section 148A(b) notice, the reassessment remained time-barred. Consequently, the writ petition was allowed, and the Section 148 notice was quashed, effectively invalidating the reassessment proceedings due to procedural time limitations.
HC held that despite considering three block periods of limitation exclusion as per SC precedents, the re-assessment notice dated 23 July 2022 exceeded statutory limitation. The court specifically noted that even after adding 14 days for assessee's response to Section 148A(b) notice, the reassessment remained time-barred. Consequently, the writ petition was allowed, and the Section 148 notice was quashed, effectively invalidating the reassessment proceedings due to procedural time limitations.
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