Second Reopening Set Aside Due to Time-Barred Section 148 Proceedings

Apcotex Industries Limited Vs ITO (ITAT Mumbai) Reassessment Time-Barred Post Rajeev Bansal: ITAT Quashes Second Reopening for AY 2013-14 The Mumbai Bench of the ITAT allowed the appeal of Apcotex Industries Ltd. for AY 2013-14, quashing the reassessment proceedings on the jurisdictional ground of limitation by applying the Supreme Court’s authoritative ruling in Union of India v. Rajeev Bansal. The case involved a second reopening where the AO issued notice under section 148 (new regime) after following the Ashish Agarwal directions. The Tribunal meticulously computed the “surviving perio...