https://www.taxtmi.com/caselaws?id=447501 The HC quashed reassessment proceedings under Section 147 due to procedural violations. The petitioner received the Section 148A(b) notice on 28.03.2022, one day before the reply deadline of 29.03.2022, but the notice was dated 23.03.2022. The court held that the seven-day period should be calculated from actual receipt, not the notice date. The AO violated natural justice principles by not providing adequate time for response. Additionally, the proceedings were time-barred as the six-year limitation period for AY 2015-16 had expired by 31.03.2021, making the reassessment notice issued in 2022 invalid. The court emphasized that the Income Tax Department cannot indefinitely pursue assessees beyond statutory limitations. en-us Tue, 31 Oct 2023 00:00:00 +0530 Thu, 28 Dec 2023 08:43:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447501 The HC quashed reassessment proceedings under Section 147 due to procedural violations. The petitioner received the Section 148A(b) notice on 28.03.2022, one day before the reply deadline of 29.03.2022, but the notice was dated 23.03.2022. The court held that the seven-day period should be calculated from actual receipt, not the notice date. The AO violated natural justice principles by not providing adequate time for response. Additionally, the proceedings were time-barred as the six-year limitation period for AY 2015-16 had expired by 31.03.2021, making the reassessment notice issued in 2022 invalid. The court emphasized that the Income Tax Department cannot indefinitely pursue assessees beyond statutory limitations. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447501