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    <title>2024 (5) TMI 963 - BOMBAY HIGH COURT</title>
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    <description>The Bombay HC quashed reassessment notices issued under Section 148 for AY 2013-14, ruling they were issued beyond the statutory limitation period. The court held that the reopening notice should have been issued within 6 years from the end of AY 2013-14, with the limitation period extended by TOLA expiring on 31st March 2021. Since the notice was issued in July 2022, it exceeded the time limit. The HC emphasized that the Supreme Court&#039;s directions in Ashish Agrawal specifically granted liberty to assessees to raise all available defences, including those under Section 149, which cannot be disregarded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=752910</link>
      <description>The Bombay HC quashed reassessment notices issued under Section 148 for AY 2013-14, ruling they were issued beyond the statutory limitation period. The court held that the reopening notice should have been issued within 6 years from the end of AY 2013-14, with the limitation period extended by TOLA expiring on 31st March 2021. Since the notice was issued in July 2022, it exceeded the time limit. The HC emphasized that the Supreme Court&#039;s directions in Ashish Agrawal specifically granted liberty to assessees to raise all available defences, including those under Section 149, which cannot be disregarded.</description>
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