https://www.taxtmi.com/caselaws?id=776563 The ITAT Mumbai upheld the validity of the reopening notice issued under section 148, confirming it was within the three-year limitation period after excluding the time allowed for the assessee's response under section 148A(d). The tribunal found prior approval under section 151 was correctly obtained before issuing the notice. The recent amendment by the Finance Act, 2023, was not considered necessary to decide at this stage. On merits, as no substantive arguments were presented and the assessment was protective pending related proceedings against the assessee's spouse, the matter was remanded to the AO for fresh adjudication after providing the assessee a reasonable opportunity. The appeal was partly allowed for statistical purposes. en-us Tue, 22 Jul 2025 00:00:00 +0530 Tue, 12 Aug 2025 12:44:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776563 The ITAT Mumbai upheld the validity of the reopening notice issued under section 148, confirming it was within the three-year limitation period after excluding the time allowed for the assessee's response under section 148A(d). The tribunal found prior approval under section 151 was correctly obtained before issuing the notice. The recent amendment by the Finance Act, 2023, was not considered necessary to decide at this stage. On merits, as no substantive arguments were presented and the assessment was protective pending related proceedings against the assessee's spouse, the matter was remanded to the AO for fresh adjudication after providing the assessee a reasonable opportunity. The appeal was partly allowed for statistical purposes. Case-Laws Income Tax Tue, 22 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776563