Reassessment Proceedings Held Void as Jurisdiction Was Assumed Beyond Limitation Period

Mangal Singh Vs ITO (ITAT Delhi) The Delhi ITAT held that reassessment proceedings initiated for Assessment Year 2015-16 were invalid as the notice issued under Section 148 of the Income Tax Act on 27.07.2022 was barred by limitation under Section 149(1). The Tribunal noted that although the CIT(A)/NFAC had correctly recognized the jurisdictional defect in the reassessment proceedings, it erred in merely setting aside the assessment instead of annulling it. Relying on the Supreme Court’s decision in Rajeev Bansal and the Delhi High Court’s ruling in MakeMyTrip India Pvt. Ltd., the ...