u/Icy-Record-4724

I have been trying to find a clear answer to this.

My understanding is that if the if the income is below 50lkh a fresh reassessment notice under Section 148 generally cannot be issued after the normal 3 years and 3 months period.

If that time has already expired, and I now file a Section 154 rectification application, can that by itself result in the Income Tax Department issuing any fresh notice (such as a reassessment, scrutiny, penalty, or any other notice) that otherwise could not have been issued?

Or does filing a Section 154 application only allow the department to deal with the rectification request itself, without reviving any expired limitation period?

If anyone knows of a relevant provision, CBDT circular, or court judgment, I'd really appreciate your guidance.

I have been trying to find a clear answer to this.

My understanding is that if the if the income is below 50lkh a fresh reassessment notice under Section 148 generally cannot be issued after the normal 3 years and 3 months period.

If that time has already expired, and I now file a Section 154 rectification application, can that by itself result in the Income Tax Department issuing any fresh notice (such as a reassessment, scrutiny, penalty, or any other notice) that otherwise could not have been issued?

Or does filing a Section 154 application only allow the department to deal with the rectification request itself, without reviving any expired limitation period?

If anyone knows of a relevant provision, CBDT circular, or court judgment, I'd really appreciate your guidance.

I have been trying to find a clear answer to this.

My understanding is that if the if the income is below 50lkh a fresh reassessment notice under Section 148 generally cannot be issued after the normal 3 years and 3 months period.

If that time has already expired, and I now file a Section 154 rectification application, can that by itself result in the Income Tax Department issuing any fresh notice (such as a reassessment, scrutiny, penalty, or any other notice) that otherwise could not have been issued?

Or does filing a Section 154 application only allow the department to deal with the rectification request itself, without reviving any expired limitation period?

If anyone knows of a relevant provision, CBDT circular, or court judgment, I'd really appreciate your guidance.