DTVSV Settlement Does Not Render Reassessment Order Non Est for Section 154 Limitation

Pushkar Chemical and Fertilisers Pvt. Ltd. Vs DCIT (ITAT Mumbai) The Income Tax Appellate Tribunal (ITAT), Mumbai, disposed of two connected appeals involving the assessee and the Revenue for Assessment Years (AY) 2012-13 and 2014-15. Both appeals arose from proceedings under Section 154 of the Income-tax Act, 1961, and primarily concerned the characterization of fertilizer subsidy received under the Government of India’s Nutrient Based Subsidy (NBS) Policy and the scope of rectification proceedings. The assessee, engaged in the manufacture of chemicals, dyes, fertilizers and bio-fertili...