Timebarred Reassessment quashed

The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has quashed reassessment proceedings for AYs 2016-17 and 2017-18 after holding that notices issued under Section 148 were barred by limitation. 

Applying the principles laid down by the Supreme Court in Rajeev Bansal and Ashish Agarwal, the Tribunal held that reassessment notices issued beyond the surviving statutory period were invalid, rendering the entire proceedings non est in law.