https://www.taxtmi.com/caselaws?id=764908 The Gauhati HC quashed a notice under Section 148 and order under Section 148A(d) for reopening assessment. The court held that the petitioner was deprived of reasonable opportunity as required under Section 148A(c), violating legislative intent. The AO's delayed action and approaching limitation period did not justify denying due process. Additionally, the court found complete non-application of mind regarding limitation periods, noting incorrect calculation of the extended limitation period for Assessment Year 2015-16. The departmental officer's late action could not excuse procedural violations. en-us Thu, 21 Nov 2024 00:00:00 +0530 Mon, 03 Mar 2025 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764908 The Gauhati HC quashed a notice under Section 148 and order under Section 148A(d) for reopening assessment. The court held that the petitioner was deprived of reasonable opportunity as required under Section 148A(c), violating legislative intent. The AO's delayed action and approaching limitation period did not justify denying due process. Additionally, the court found complete non-application of mind regarding limitation periods, noting incorrect calculation of the extended limitation period for Assessment Year 2015-16. The departmental officer's late action could not excuse procedural violations. Case-Laws Income Tax Thu, 21 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764908