Held that the old assessments have been passed on the strength of notices issued under section 148 of the Act which was not in existence on the day of its issuance, i. e., June 30, 2021. Therefore, no assessment orders could be passed. The assessment orders dated March 31, 2022 were invalid assessments and were quashed.(AY. 2018-19 to 2020-21)
G D Mother Educational Society v. ACIT (2024)115 ITR 594 / [2025] 170 taxmann.com 667 (Kol)(Trib)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Delay condoned-Additional ground-Earlier orders passed on basis of notice under Section 148 is not existing on date of notice-Assessment is invalid and quashed.[S. 147, 253(5), ITATR. 11]