Reassessment Notices Quashed: Time-Bar under Rajeev Bansal & Invalid Section 151 Approval

ITO Vs LNG Agricom Private Limited (ITAT Delhi) Delhi ITAT examined jurisdictional defects in reassessment proceedings for AYs 2015-16 & 2016-17. In CO No.219 (AY 2015-16), Assessee argued that notice u/s 148 dated 30.06.2021 was barred by limitation u/s 149, relying on Supreme Court ruling in UOI Vs Rajeev Bansal, which held that reassessment notices must fall within surviving six-year period even after exclusion under Ashish Agarwal mechanism. Tribunal held that notice dated 30.06.2021 for AY 2015-16 exceeded permissible six-year window & was therefore time-barred; consequent reasse...