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ITAT quashed reassessment notice under Section 148 issued on 20/07/2022 for Assessment Year 2017-18, holding it time-barred. Following Supreme Court precedent in UOI vs. Ashish Agarwal, the three-year limitation period expired on 31/03/2021. Although notices issued between 01/04/2021 and 30/06/2021 were deemed issued on 31/03/2021, the extended period for completing Section 148A procedures under new provisions was available only until 30/06/2021. Revenue had merely 20 days to complete entire procedure under Section 149(1) and issue fresh notice under new regime. Since notice was issued beyond limitation period, it was quashed and consequent reassessment order declared void ab initio. Assessee's appeal succeeded on limitation grounds.
ITAT quashed reassessment notice under Section 148 issued on 20/07/2022 for Assessment Year 2017-18, holding it time-barred. Following Supreme Court precedent in UOI vs. Ashish Agarwal, the three-year limitation period expired on 31/03/2021. Although notices issued between 01/04/2021 and 30/06/2021 were deemed issued on 31/03/2021, the extended period for completing Section 148A procedures under new provisions was available only until 30/06/2021. Revenue had merely 20 days to complete entire procedure under Section 149(1) and issue fresh notice under new regime. Since notice was issued beyond limitation period, it was quashed and consequent reassessment order declared void ab initio. Assessee's appeal succeeded on limitation grounds.
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