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The HC held that reopening notices issued under section 148 between 01.04.2021 and 30.06.2021, treated as deemed notices under section 148A(b), followed by show-cause notices and orders under section 148A(d), and subsequent reassessment notices issued post-July 2022, were subject to the limitation regime under the amended provisions. Applying the Supreme Court's ruling in Rajeev Bansal, the court found that the impugned reassessment notices were issued beyond the prescribed limitation period. Consequently, all such notices were declared time-barred and quashed. The assessee's appeal was allowed, thereby invalidating the reopening of assessments under section 147 due to non-compliance with the statutory limitation framework as amended and extended during the COVID-19 period.
The HC held that reopening notices issued under section 148 between 01.04.2021 and 30.06.2021, treated as deemed notices under section 148A(b), followed by show-cause notices and orders under section 148A(d), and subsequent reassessment notices issued post-July 2022, were subject to the limitation regime under the amended provisions. Applying the Supreme Court's ruling in Rajeev Bansal, the court found that the impugned reassessment notices were issued beyond the prescribed limitation period. Consequently, all such notices were declared time-barred and quashed. The assessee's appeal was allowed, thereby invalidating the reopening of assessments under section 147 due to non-compliance with the statutory limitation framework as amended and extended during the COVID-19 period.
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