AKASH SHAH vs THE ASSISTANT COMMISSIONER OF INCOME-TAX

Whether notice issued u/s 148 of the Income Tax Act dated 08.04.2021 for A.Y. 2015-16 is barred by limitation and invalid in view of TOLA and the decisions in Union of India vs. Rajeev Bansal and Deepak Steel & Power Ltd. --- Held Yes, notice is time-barred and void ab initio; consequent assessment order u/s 147 r.w.s 144B quashed. Whether delay of 23 days in filing appeal should be condoned --- Held Yes.

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