https://www.taxtmi.com/caselaws?id=768381 Delhi HC held that reassessment proceedings under Section 148 were invalid due to limitation period expiry. The first Section 148 notice was issued on 23.06.2021, six days before the extended deadline of 30.06.2021 under TOLA. Following Supreme Court directions in Union of India v. Ashish Agarwal, this notice was treated as Section 148A(b) notice. However, the second Section 148 notice was issued beyond the seven-day limitation period after the assessee's response on 07.06.2022. HC set aside all subsequent proceedings, finding the second notice time-barred without examining parallel Section 153C proceedings or competent authority approval issues. en-us Tue, 25 Mar 2025 00:00:00 +0530 Tue, 10 Mar 2026 15:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768381 Delhi HC held that reassessment proceedings under Section 148 were invalid due to limitation period expiry. The first Section 148 notice was issued on 23.06.2021, six days before the extended deadline of 30.06.2021 under TOLA. Following Supreme Court directions in Union of India v. Ashish Agarwal, this notice was treated as Section 148A(b) notice. However, the second Section 148 notice was issued beyond the seven-day limitation period after the assessee's response on 07.06.2022. HC set aside all subsequent proceedings, finding the second notice time-barred without examining parallel Section 153C proceedings or competent authority approval issues. Case-Laws Income Tax Tue, 25 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768381