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ITAT Raipur: Section 148 Notice Issued Beyond Limitation Period is Invalid

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Summary

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  • The ITAT Raipur has quashed a reassessment notice issued under Section 148 of the Income Tax Act, 1961, citing it as time-barred.
  • The notice, dated 27 July 2022, was deemed invalid as it exceeded the surviving limitation period for the Assessment Year 2013-14.
  • The Tribunal relied on precedents including the Supreme Court's ruling in Union of India v. Rajeev Bansal to support its decision.
  • This ruling underscores the critical importance of adhering to statutory timelines in tax reassessment proceedings, potentially impacting future cases.

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