Reassessment Time barred

The ITAT held that the reassessment notice issued under Section 148 on 27 August 2022 was time-barred as the statutory surviving period of 56 days had expired on 10 August 2022. 

The Tribunal quashed both the notice under Section 148 and the consequential assessment order under Sections 147/143(3), following the Supreme Court's rulings in Ashish Agarwal and Rajeev Bansal.