Mohmedmunaf Noormohmed Cambaywala v. ITO (2026) 310 Taxman 703 (Guj)(HC)

S. 149: Reassessment-Time limit for notice-For assessment year 2015-16, all notices issued on or after 1-4-2021 under sections 148 and 148A were liable to be dropped as they did not fall within the period prescribed under TOLA.[S. 147, 148, 148A(b), 148A(d), TOLA, Art. 226]

Court held that for assessment year 2015-16, all notices issued on or after 1-4-2021 under sections 148 and 148A were liable to be dropped as they did not fall within period prescribed under TOLA. Since issue was squarely covered by decision of Apex Court in Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70/469 ITR 46/301 Taxman 238 (SC) as well as various decisions of High Court, notices under sections 148 and 148A challenged in present writ petition, and all consequential proceedings including reassessment order, were quashed.  (AY. 2015-16)

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