Reassessment Notice U/s 149(1) Invalid Due To Time-Bar Despite TOLA Extension And Section 148A Requirements

HC determined the reassessment notice issued on 30.07.2022 was time-barred under Section 149(1). While TOLA provided AO twenty-nine days limitation period from 01.06.2021, and considering the two-week response time given to assessee under Section 148A(b), the limitation period expired on 12.07.2022. The court found the notice issued on 30.07.2022 was beyond prescribed limitation. The fourth proviso to Section 149 was inapplicable as AO had sufficient time to pass order under Section 148A(d). The HC quashed both the order under Section 148A(d) and notice under Section 148, ruling in assessee's favor due to the procedural time-bar. .....

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