Vikash Agarwal Vs. ITO, Ward 3(1)

Parties Involved

Facts Summary

The facts in brief are that the notice under section 148 of the Act was issued on 19.06.2021. The assessee requested the Assessing Officer (AO)/Joint Assessing Officer (JAO) on 06.01.2022 for supplying the reasons filed with JAO on 07.01.2022. On 03.02.2022, the reasons were supplied by the JAO to the assessee. Thereafter the AO issued show cause notice under section 148A(b) of the Act on 23.05.2022, calling upon the assessee to reply by 08.06.2022. The assessee replied to the notice dated 23.05.2022 by uploading the reply on 08.06.2022. Again another notice was issued under section 148A(b) of the Act by the AO calling upon the assessee to make compliance by 20th June, 2022. The assessee filed the online reply on 20.06.2022. Thereafter, the AO passed order under section 148A(d) of the Act and noted that this is a fit case for issue of notice. Thereafter, the notice was issued under section 148 of the Act by JAO, ITO ward 3(1), Kolkata on 30.07.2022.…

Legal Issues

• 1. Whether the notice issued under section 148 of the Act and the reassessment proceedings are barred by limitation.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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