The ITAT ruled that an Income Tax notice issued after April 1, 2021, is time-barred under the TOLA concession, emphasizing adherence to statutory deadlines in tax assessments.
ITAT Quashes Time-Barred Income Tax S. 148 Notice Issued After April 1, 2021
The Income Tax Appellate Tribunal (ITAT) has quashed a notice issued under Section 148 of the Income Tax Act because it was sent after the stipulated deadline of April 1, 2021. The Tribunal placed strong emphasis on the TOLA concession acknowledged in the Rajiv Bansal case.
This decision illustrates the critical nature of adhering to statutory timelines for tax assessments and re-assessments. The Tribunal held that the issuance of such notices post-deadline renders the proceedings invalid and time-barred.
Practitioners should reinforce the importance of complying with prescribed timelines in tax matters, as this ruling sets a precedent that can impact future cases involving late-issued notices and ensure taxpayers' rights are protected against procedural lapses.
Citations
- ITAT Quashing of Notice Case (2026) ITAT 3
