Extended Limitation Cannot Apply to Expense Disallowances

ACIT Vs Brij Bhushan Gupta (ITAT Delhi) Expenditure Is Not an ‘Asset’: ITAT Quashes Reassessments for AYs 2013-14 & 2015-16 as Time-Barred The Delhi Bench of the Income Tax Appellate Tribunal allowed the assessee’s cross-objections and quashed the reassessment proceedings for AYs 2013-14 and 2015-16, holding that the notices issued under section 148 were barred by limitation under the post-Finance Act, 2021 regime. Consequently, the Revenue’s appeals were dismissed as infructuous. For AY 2015-16, the Tribunal noted that the Revenue had conceded before the Supreme Court (in UOI ...