Purohit Food Products Private Limited Vs ITO (ITAT Mumbai)
In the case of Purohit Food Products Pvt. Ltd. vs. Income Tax Officer, the ITAT Mumbai addressed the appeal challenging the dismissal of a late appeal due to a delay of 198 days. The delay was attributed to the appellant’s lack of awareness of the assessment order and the medical treatment of a key director. The core issue was the legality of a reassessment notice issued on July 29, 2022, for the assessment year 2015-16, which the appellant argued was barred by limitation. The appellant relied on the recent Bombay High Court ruling in Hexaware Technologies Ltd., which invalidated a similar notice issued after March 31, 2021. The ITAT Mumbai agreed with this precedent, ruling that the notice issued was indeed time-barred according to the previous legal provisions, thus quashing the reassessment orders. This decision reinforces the High Court’s stance that reassessment notices issued beyond the legal deadlines are invalid. The ITAT’s ruling emphasizes adherence to established legal timelines for tax reassessments and the importance of timely notice issuance.
FULL TEXT OF THE ORDER OF ITAT MUMBAI
The assessee has filed this appeal challenging the order dated 27-03-2024 passed by the learned Commissioner of Income Tax (Appeals)-NFAC, Delhi (in short “Ld.CIT(A)”) and it relates to AY. 2015-16.
