Reopening for AY 2015-16 After 01.04.2021 Invalid – ITAT Quashes U/s 148 Notice as Time-Barred

Varun Enterprises Vs ACIT (ITAT Mumbai) The ITAT Mumbai quashed the reassessment proceedings, holding that notice issued under Section 148 on 29.06.2022 for AY 2015–16 was barred by limitation under Section 149. The Tribunal noted  that: The 6-year limitation period expired on 31.03.2022, The notice was issued after this date, and hence beyond the permissible time limit. Relying on binding precedents of the Supreme Court in Union of India vs. Rajeev Bansal and Deepak Steel & Power Ltd., as well as the Bombay High Court ruling in Mitra Biswas, the ITAT held that: Reopening of AY 2015â...