Dismissing the petition the Court held that the date of issuing the initial notice under section 148A(b) was the relevant and crucial date for the purpose of limitation period. The initial notice dated March 28, 2024, issued under section 148A(b), was within the limitation period prescribed under section 149(1)(a). The subsequent notice dated April 22, 2024 was issued in response to the assessee’s reply dated March 31, 2024 and did not affect the validity of the reassessment proceedings under section 147. (AY. 2020-21)
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