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HC dismissed the writ petition, holding that the Assessing Officer (AO) had valid jurisdiction to reopen assessment for 2020-21. The AO issued notice u/s 148A(b) on 28.03.2024, which was within the prescribed three-year limitation period. The court found that the first notice dated 28.03.2024 was crucial for determining the limitation timeline, and the subsequent notice on 22.04.2024 was immaterial. The petition was deemed premature, with liberty granted to the petitioner to participate in the assessment proceedings and cooperate with the revenue authorities.
HC dismissed the writ petition, holding that the Assessing Officer (AO) had valid jurisdiction to reopen assessment for 2020-21. The AO issued notice u/s 148A(b) on 28.03.2024, which was within the prescribed three-year limitation period. The court found that the first notice dated 28.03.2024 was crucial for determining the limitation timeline, and the subsequent notice on 22.04.2024 was immaterial. The petition was deemed premature, with liberty granted to the petitioner to participate in the assessment proceedings and cooperate with the revenue authorities.
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