https://www.taxtmi.com/caselaws?id=764114 ITAT Mumbai held that notice under section 148 issued on 27/07/2022 was barred by limitation as the six-year period had expired on 31/03/2022. The tribunal applied the test that validity of section 148 notices depends on whether six years had expired at the time of issuance, regardless of whether new or prior regime applies. Consequently, the assessment proceedings under section 147 were quashed on limitation grounds. en-us Tue, 31 Dec 2024 00:00:00 +0530 Fri, 03 Jan 2025 08:45:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764114 ITAT Mumbai held that notice under section 148 issued on 27/07/2022 was barred by limitation as the six-year period had expired on 31/03/2022. The tribunal applied the test that validity of section 148 notices depends on whether six years had expired at the time of issuance, regardless of whether new or prior regime applies. Consequently, the assessment proceedings under section 147 were quashed on limitation grounds. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764114