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ITAT allowed the assessee's appeal, quashing the notice issued under section 148A and all consequential proceedings including assessment orders. The tribunal held that the assessing officer failed to provide the mandatory minimum seven-day response period prescribed under section 148A(b) for the assessee to respond to the notice. Following the precedent established in Thulaseedas Srinath case, ITAT determined that granting insufficient time below the statutory minimum requirement rendered the entire notice procedurally invalid. Consequently, all subsequent proceedings stemming from the defective notice, including assessment orders, were deemed null and void, resulting in complete relief for the assessee.
ITAT allowed the assessee's appeal, quashing the notice issued under section 148A and all consequential proceedings including assessment orders. The tribunal held that the assessing officer failed to provide the mandatory minimum seven-day response period prescribed under section 148A(b) for the assessee to respond to the notice. Following the precedent established in Thulaseedas Srinath case, ITAT determined that granting insufficient time below the statutory minimum requirement rendered the entire notice procedurally invalid. Consequently, all subsequent proceedings stemming from the defective notice, including assessment orders, were deemed null and void, resulting in complete relief for the assessee.
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