Amended Reassessment Provisions Cannot Reopen Years Already Barred Under Old Law

DCIT Vs Southern Agrifurane –Industries Pvt. Ltd (ITAT Chennai)

The appeals before the Income Tax Appellate Tribunal (ITAT), Chennai ‘C’ Bench, arose from cross-appeals filed by the Revenue and the assessee for Assessment Years (AYs) 2013-14 to 2016-17. The dispute related to reassessment proceedings initiated after a search conducted under section 132 of the Income Tax Act, 1961 on 15.06.2022.

The assessee was engaged in the business of manufacturing and sale of Indian Made Foreign Liquor. During the search, the Revenue claimed to have seized books of account, docume

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