Section 148 Notice Issued Beyond Surviving Time Invalid: ITAT Delhi

DCIT Vs Rajan Kumar (ITAT Delhi) Reassessment Notice Time-Barred Despite Ashish Agarwal Relief – ITAT Delhi Applies Rajeev Bansal Ratio The Bench of the ITAT dismissed the Revenue’s appeal for AY 2013-14 and upheld the quashing of reassessment proceedings on the ground of limitation under section 149, even in cases covered by the Supreme Court’s decision in Ashish Agarwal. In this case, the original notice under section 148 (old regime) was issued on 17.06.2021. Pursuant to Ashish Agarwal, the notice was deemed to be a show-cause notice under section 148A(b), and the assessee submitted i...