Section 147 Proceedings Invalid Due to Limitation, ₹3.34 Cr Addition Dropped

Mohd. Ayyub Vs ITO (ITAT Delhi) Time-barred notice kills reassessment: ITAT quashes 147 proceedings for AY 2015-16 relying on Rajeev Bansal- For AY 2015-16, notice could have been issued only up to 31-03-2022, subject to ₹50 lakh escapement condition Delhi ITAT allowed Assessee’s appeal &  quashed reassessment proceedings as being barred by limitation. Tribunal admitted additional legal ground under Rule 11, holding that validity of notice u/s 148 can be examined on admitted facts, relying on NTPC Ltd vs CIT. ITAT noted that notice u/s 148 was issued on 22-07-2022 for AY 2015-16, whic...