Reassessment Notice Invalidated: Limitation Periods Exceeded, Section 148 Notice Quashed After Detailed Statutory Analysis

HC held that despite considering three block periods of limitation exclusion as per SC precedents, the re-assessment notice dated 23 July 2022 exceeded statutory limitation. The court specifically noted that even after adding 14 days for assessee's response to Section 148A(b) notice, the reassessment remained time-barred. Consequently, the writ petition was allowed, and the Section 148 notice was quashed, effectively invalidating the reassessment proceedings due to procedural time limitations. .....

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