https://www.taxtmi.com/caselaws?id=467348 Notices under section 148 issued after the Ashish Agarwal legal fiction must fall within the surviving limitation period computed by excluding the stay period and the time allowed to the assessee to respond; where that surviving period has expired, a fresh 148 notice and any consequent order under section 147 are time barred. Applying the Rajiv Bansal clarification and co-ordinate decisions, the ITAT found the 28.07.2022 and 29.07.2022 notices to be beyond the surviving limitation period and therefore invalid, and held consequential reassessment orders void ab initio, allowing the appeals in favour of the assessee. en-us Wed, 03 Sep 2025 00:00:00 +0530 Sun, 15 Mar 2026 16:36:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467348 Notices under section 148 issued after the Ashish Agarwal legal fiction must fall within the surviving limitation period computed by excluding the stay period and the time allowed to the assessee to respond; where that surviving period has expired, a fresh 148 notice and any consequent order under section 147 are time barred. Applying the Rajiv Bansal clarification and co-ordinate decisions, the ITAT found the 28.07.2022 and 29.07.2022 notices to be beyond the surviving limitation period and therefore invalid, and held consequential reassessment orders void ab initio, allowing the appeals in favour of the assessee. Case-Laws Income Tax Wed, 03 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467348