https://www.taxtmi.com/caselaws?id=777751 ITAT KOLKATA - AT held the section 148 notice dated 26.07.2022 was time-barred and reassessment under section 147/148 was invalid. Applying post-31.03.2021 amendments, the Supreme Court directions treating certain 148 notices as 148A(b) show-cause notices, the provisos to section 149(1) and TOLA extensions, the tribunal excluded periods mandated for furnishing material and for the assessee to reply. The "surviving time" for issuing a fresh 148 notice expired on 08.06.2022, so issuance on 26.07.2022 lacked jurisdiction and proceedings founded thereon were set aside. en-us Thu, 28 Aug 2025 00:00:00 +0530 Thu, 04 Sep 2025 08:40:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777751 ITAT KOLKATA - AT held the section 148 notice dated 26.07.2022 was time-barred and reassessment under section 147/148 was invalid. Applying post-31.03.2021 amendments, the Supreme Court directions treating certain 148 notices as 148A(b) show-cause notices, the provisos to section 149(1) and TOLA extensions, the tribunal excluded periods mandated for furnishing material and for the assessee to reply. The "surviving time" for issuing a fresh 148 notice expired on 08.06.2022, so issuance on 26.07.2022 lacked jurisdiction and proceedings founded thereon were set aside. Case-Laws Income Tax Thu, 28 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777751