Section 153C Proceedings Quashed as Time-Barred & Below ₹50 Lakh Threshold: ITAT Delhi

Neha Gupta Vs ACIT (ITAT Delhi) Section 153C Proceedings Quashed as Time-Barred and Below ₹50 Lakh Threshold: ITAT Delhi Follows Delhi High Court The Delhi Bench of the ITAT allowed the assessee’s appeals for AYs 2014-15 and 2015-16 and quashed the notices issued under section 153C as well as the consequential assessment orders, holding them to be barred by limitation and without jurisdiction. The Tribunal noted that the satisfaction note was recorded on 23.06.2022 and notice under section 153C was issued on 29.06.2022. On these dates, the impugned assessment years fell beyond the permissi...