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Reassessment Notice invalid if approved by JCIT instead of Pr.CIT after four years
Case Law Details
- Case Name
- ACIT Vs SBK Trade And Infrastructure Pvt. Ltd. (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All ITAT, ITAT Delhi
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ACIT Vs SBK Trade And Infrastructure Pvt. Ltd. (ITAT Delhi)
Reopening Beyond 4 Years Quashed: ITAT Delhi Applies Rajeev Bansal—JCIT Approval Invalid, 148 Notice Time-Barred; TOLA 2020 does not extend deadlines for notices issued after March 2021
Assessee challenged the reopening u/s 148 on the ground that the approval was taken from the JCIT, Range-22, whereas for a notice issued after four years from the end of AY 2015-16, the law mandates approval of the Pr.CIT u/s 151(1). The notice dated 31.03.2021 was issued with JCIT approval based on the Revenue’s interpretation of ...





