Notice Under Section 148 Quashed for Reassessment Without Tangible Evidence

Rupa Infotech & Infrastructure Pvt. Ltd. Vs DCIT (ITAT Mumbai) CBDT-Approved Tech Park: ITAT Quashes 148 Beyond Four Years in 80IA Case- AO Cannot Re-Review Old Facts—Reopening Held Void No New Material, No Reopening Tribunal considered Assessee’s challenge to reopening u/s 147 & disallowance of deduction u/s 80IA(4)(iii). Assessee had developed a CBDT-approved Software Technology Park satisfying the 52-unit condition, & AO had already allowed deduction of Rs.4.69 crore during original assessment u/s 143(3). Reopening was done on 28.03.2019—beyond four years—based only on ...