Income Tax Reassessment Notice Quashed: Time-Barred Under Section 149(1), TOLA Extension Deadline Not Met

HC quashed reassessment notice dated 30.07.2022 for AY 2013-14 as time-barred under s.149(1) of IT Act. Court held that 29-day extension under TOLA required completion of both s.148A(d) order and s.148 notice by 12.07.2022. Despite procedural timeline of one month under s.148A(d), AO was bound by overarching limitation period. Court applied SC decisions in Ashish Agarwal and Rajeev Bansal to calculate available time, excluding periods between 01.06.2021-04.05.2022 and 04.05.2022-30.05.2022. Since notice was issued on 30.07.2022, beyond calculated deadline, proceedings were invalid. HC rejected Revenue's argument that s.148A(d) timeline operated independently of s.149 limitation. .....

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