Held that notice for asst. yr. 2015-16 issued on 15th July, 2022 under S 148 is barred by limitation and hence bad in law, and therefore, impugned reassessment proceedings as well as the impugned reassessment order are bad in law. Followed UOI v. Rajeev Bansal (2024) 340 CTR 865 (SC) (AY.2015-16)
Mark Foods v. ITO (2025) 235 TTJ 251 (Mum) Trib)
S. 149: Reassessment-Time limit for notice-Notice issued after expiry of six years from the end of relevant assessment year-Notice for asst. yr. 2015-16 issued on 15th July, 2022 under s. 148 is barred by limitation, hence bad in law [S. 148]
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