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The ITAT held that the notice issued under section 148 of the Act dated 31.03.2021 but served on the assessee on 03.04.2021 is invalid and barred by limitation. The Tribunal relied on precedents establishing that notices issued after the limitation period, even if dated within it, do not validate reassessment proceedings under the amended provisions effective from 01.04.2021. Since the Assessing Officer failed to comply with the new procedural requirements under sections 148 read with 148A for reassessment initiated post-amendment, the reassessment for A.Y. 2016-17 was quashed as bad in law. The appeal of the assessee was allowed, confirming that the reassessment proceedings triggered by the impugned notice stand invalidated due to non-compliance with the statutory time limits and procedural mandates.
The ITAT held that the notice issued under section 148 of the Act dated 31.03.2021 but served on the assessee on 03.04.2021 is invalid and barred by limitation. The Tribunal relied on precedents establishing that notices issued after the limitation period, even if dated within it, do not validate reassessment proceedings under the amended provisions effective from 01.04.2021. Since the Assessing Officer failed to comply with the new procedural requirements under sections 148 read with 148A for reassessment initiated post-amendment, the reassessment for A.Y. 2016-17 was quashed as bad in law. The appeal of the assessee was allowed, confirming that the reassessment proceedings triggered by the impugned notice stand invalidated due to non-compliance with the statutory time limits and procedural mandates.
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