Regarding reopening of case after period mentioned in 148

Notice u/s 148 was issued on 05.04.2022 for A.Y 2018-19 after completing the formalities of issue of notice u/s 148A(b) and order u/s 148A(d). The assessment was going on. In the meantime assessee received notice u/s 153C dt 18.01.2023 in a search matter conducted on 20.10.2019 and therefore proceeding u/s 148 got abated. AO pass the assessment order u/s 153C on 13.02.2024 at returned income. Thereafter assesse received notice u/s 263 from CIT mentioning that AO has not discussed the issue raised while opening case u/s 148. It is also alleged that he did not make any inquiry about matter…

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