Sainik Co-operative House Building Society Ltd. v. ITO (2025) 214 ITD 595 (Amritsar) (Trib.)

S. 149: Reassessment-Time limit for notice-Cash deposits-Notice under section 148A in July 2022-Revised notice period for assessment year 2013-14 expired on 26 June 2022-Notice issued on 25 th July 2022 was barred by limitation.[S. 69A, 147, 148, 148A(b), 148A(d)]

 Assessee did not file a return, and cash deposits resulted in a reassessment notice under section 148A in July 2022. Tribunal held that since the Supreme Court clarified in UOI v. Rajeev Bansal (2024) 301 Taxman 238/ 469 ITR 46 (SC)  that revised notice period for assessment year 2013-14 expired on 26 June 2022, the notice issued on 25 July 2022 was barred by limitation and the entire reassessment proceedings were not legally valid and were quashed.  (AY. 2013-14)

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