Income Tax
Lucknow Income Tax Appellate Tribunal rules notices issued between 21 and 26 March invalid
Originally reported by Taxguru as: Income Tax | Section 148A(b) Notice from 21 to 26 March Invalid: Lucknow ITAT
6 Nov 2026, 2:49 pm IST · Xecute.finance News Desk
The crisp read
The Lucknow Income Tax Appellate Tribunal has declared Section 148A(b) notices issued within the specific date window of 21 to 26 March as legally invalid. This decision provides substantial relief to assessees facing reassessment proceedings initiated during that specific timeframe.
Xecute Impact Breakdown
For CAs
- Audit all client files to identify any Section 148A(b) notices received during the invalidated March window.
- File appropriate rectification or appeal petitions before the relevant authorities.
- Monitor further appellate developments and jurisprudence regarding Section 148A(b) reassessment proceedings.
For businesses
- Review income tax notices received to check if a Section 148A(b) notice was issued during the restricted timeframe of 21 to 26 March.
- Consult tax practitioners regarding reassessment proceedings initiated during the invalidated March bracket to assess validity.
Deep dive - the full story
The Income Tax Appellate Tribunal (ITAT) in Lucknow has ruled that statutory notices issued under Section 148A(b) of the Income Tax Act during the restricted timeframe of 21 to 26 March are null and void. This decision addresses procedural challenges raised regarding the validity of reassessment proceedings initiated by the revenue department during those specific dates. Section 148A(b) of the income tax statute mandates that tax authorities provide assessees with an opportunity to be heard before issuing a formal reassessment notice, requiring strict adherence to prescribed timelines and procedural safeguards.
In past assessment cycles, notices issued toward the fiscal year-end occasionally faced challenges regarding compliance windows, whereas the latest tribunal ruling definitively sets aside notices dispatched within the 21 to 26 March bracket due to legal infirmities. Tax practitioners and chartered accountants must audit all client files to identify any Section 148A(b) notices received during the invalidated March window and file appropriate rectification or appeal petitions before the relevant authorities.
Professionals should monitor further appellate developments and jurisdictional rulings concerning fiscal year-end notice issuances. Bottom line: check your clients' assessment records immediately to quash invalid notices and prevent unwarranted tax reassessments.
Source: taxguru.in
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