03 September 2025
Sir, inorder to count the time limit ie. less then three years or more than three year, whether the notice date of 148(b) is to be considered ? or the notice date of 148 is to be considered.
03 September 2025
Always check the date on which the Assessing Officer issues the Section 148 notice to determine if it falls within the "less than three years" or "more than three years" time frame. The Section 148A(b) notice date is relevant for compliance and chronology, but the computation for limitation period is anchored to the Section 148 notice issuance date. The date that matters for the reassessment time limit under Section 148 is the date of the notice under Section 148, not Section 148A(b).