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In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations
Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 439/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) Ashok Rudraraju, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Visakhapatnam. Pan: Aqvpr4058L
39,061/-, i.e., substantially less than the threshold amount of Rs. 50 lakhs, therefore, the notice issued under section 148 of the Act, dated 27/07/2022, was barred by limitation as per the provisions of section 149(1)(b) of the Act (as was applicable w.e.f 01/04/2021), as the said notice was issued beyond three years from