Reassessment for Bogus Purchases Quashed: Approval by Pr.CIT Invalid After 3 Years

Bysol Enterprises Pvt Ltd Vs ACIT (ITAT Mumbai) The assessee’s assessment for AY 2017-18 was reopened alleging bogus purchases of ₹4.66 crore from an alleged accommodation entry provider. Though the original notice was issued in April 2021 under the old law, after the Supreme Court’s decision in Ashish Agarwal the proceedings were converted to the new regime and a fresh order under section 148A(d) and notice under section 148 were issued on 19.07.2022. By that date, more than three years had elapsed from the end of AY 2017-18 (i.e. beyond 31.03.2021). Under the post-2021 reassessment law...