Held that the notice issued under section 148 is issued after March 31, 2021, under the new regime of reassessment, which is barred by limitation. Hence all subsequent proceedings on the basis of the notices, being not sustainable in law. Order is quashed. According to the assessee, per its books of account, there is no transactions with the four parties mentioned in the reasons recorded by the Assessing Officer. There is only one transaction with each of these parties of taking a short-term loan, which was repaid in about two years. The notice issued by the Assessing Officer under section 148A(b) had been comprehensively replied to controverting the allegations as incorrect and baseless. Assessment is quashed. (AY. 2014-15, 2016-17)
Venkateswar Medicare P. Ltd. v. ITO (2024)115 ITR 325 /231 TTJ 791 / 169 taxmann.com 460 (Kol)(Trib)
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation–Notice issued on 30-6-2021 will not relate back to original date where limitation expired on 31-3-2021-Notice is barred by limitation-Order and consequential notice is set aside-Information from Investigation wing-Accommodation entries-Charges are incorrect-Assessment made without application of mind-Notice and order is quashed. [S. 147, 148, 148A(b), 148A(d)]