Reopening Quashed for Lack of Disclosure Failure

A.T. Invofin India Private Limited Vs DCIT (ITAT Delhi) Reopening Beyond Four Years Without Alleging Assessee’s Failure Is Invalid: Delhi ITAT Quashes 148 Notice in Penny-Stock Case Assessee, a NBFC managing investments & securities transactions, filed return declaring loss of Rs.2.98 crore. Assessment u/s 143(3) was completed on 25.03.2016. After lapse of four years, AO issued notice u/s 148 on 30.03.2021 based on Investigation Wing alleging fictitious losses in transactions of Stampede Capital Ltd. & Atlanta Infra & Finance Ltd. AO stated that assessee failed to disclose fully ...