https://www.taxtmi.com/caselaws?id=752249 The Bombay HC quashed a reassessment notice dated 27th August 2022 issued under Section 148 on multiple grounds. The court held that TOLA provisions were not applicable for Assessment Year 2015-2016, and the notice was barred by limitation even after excluding specified periods. The notice was invalid for lacking a DIN and being issued by JAO instead of FAO under the faceless assessment scheme. The court found no valid reason to believe income had escaped assessment regarding Section 80JJAA deduction claims, as the original assessment had allowed these deductions. The reassessment constituted an impermissible change of opinion since the assessing officer had previously accepted the deduction claims with proper documentation. en-us Fri, 03 May 2024 00:00:00 +0530 Fri, 12 Jul 2024 10:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752249 The Bombay HC quashed a reassessment notice dated 27th August 2022 issued under Section 148 on multiple grounds. The court held that TOLA provisions were not applicable for Assessment Year 2015-2016, and the notice was barred by limitation even after excluding specified periods. The notice was invalid for lacking a DIN and being issued by JAO instead of FAO under the faceless assessment scheme. The court found no valid reason to believe income had escaped assessment regarding Section 80JJAA deduction claims, as the original assessment had allowed these deductions. The reassessment constituted an impermissible change of opinion since the assessing officer had previously accepted the deduction claims with proper documentation. Case-Laws Income Tax Fri, 03 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752249