https://www.taxtmi.com/caselaws?id=758411 Delhi HC quashed reassessment proceedings initiated under Section 148A(b) after the limitation period expired. The court held that while the SC in Ashish Agarwal allowed treating Section 148 notices as Section 148A notices, this was only for impugned notices, not for creating new proceedings. Since the original Section 148 notice was never challenged and the fresh Section 148A(b) notice was issued after the March 31, 2022 deadline, it violated the First Proviso to Section 149(1). The reassessment action was time-barred and the notice could not be treated as continuation of the original unchallenged notice. en-us Mon, 09 Sep 2024 00:00:00 +0530 Mon, 09 Jun 2025 16:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758411 Delhi HC quashed reassessment proceedings initiated under Section 148A(b) after the limitation period expired. The court held that while the SC in Ashish Agarwal allowed treating Section 148 notices as Section 148A notices, this was only for impugned notices, not for creating new proceedings. Since the original Section 148 notice was never challenged and the fresh Section 148A(b) notice was issued after the March 31, 2022 deadline, it violated the First Proviso to Section 149(1). The reassessment action was time-barred and the notice could not be treated as continuation of the original unchallenged notice. Case-Laws Income Tax Mon, 09 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758411