ITAT Quashes ₹11.23 Cr Reassessment as Section 148 Notice Held Time-Barred

DCIT Vs Sterling Agro Industries Limited (ITAT Delhi) The appeal before the Income Tax Appellate Tribunal, Delhi Bench, concerned reassessment proceedings for AY 2014-15 where the Assessing Officer added Rs. 11.23 crore alleging accommodation entries in the form of bogus milk sales. The Commissioner (Appeals) had allowed the assessee’s appeal, holding that the notice issued under Section 148 on 27.07.2022 was time-barred under Section 149, considering the Supreme Court’s rulings in Union of India v. Ashish Agarwal and Rajeev Bansal. The Tribunal examined the limitation timeline and noted t...