Second Reassessment Notice Cannot Cure Limitation Defect: ITAT Delhi

Sanjeev Kumar Aggarwal Vs DCIT (ITAT Delhi) Reassessment for AY 2015-16 Barred by Limitation – ITAT Delhi Applies Rajeev Bansal and Quashes Assessment The Delhi Bench of the ITAT allowed the assessee’s appeal for AY 2015-16 and quashed the reassessment proceedings on the ground that the notice issued under section 148 dated 26.07.2022 was time-barred. The Tribunal examined the entire chronology of events post Ashish Agarwal and applied the binding ratio of the Supreme Court in Union of India v. Rajeev Bansal. The ITAT noted that for AY 2015-16, the normal six-year limitation expired on 31....