Ramadoss Srikanthi v. ACIT (2025) 481 ITR 126 / 174 taxmann.com 150 (Mad)(HC)

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice dated 31-3-2021 under section 148 was issued within extended limitation period under section 149(1)(b) as it stood till 31-3-2021-Notice is not time barred even after application of first proviso to section 149 as amended with effect from 1-4-2021. [S. 148, 148A(b) 148A(d), 149(1)(b), Art. 226]

 

Dismissing the petition the Court held that notice dated 31-3-2021 under section 148 was issued within extended limitation period under section 149(1)(b) as it stood till 31-3-2021-Notice is not time barred even after application of first proviso to section 149 as amended with effect from 1-4-2021. (AY. 2015-16)

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