No TOLA Shelter: ITAT Delhi Quashes 2015-16 Reopenings as Time-Barred

Gurcharan Singh Vs ITO (ITAT Delhi) Assessees challenged reassessment orders framed u/s 147 r.w.s. 144 for AY 2015-16 pursuant to notices issued u/s 148 on 20.07.2022 & 21.07.2022. Both assessees argued that the reopening was invalid as it was barred by limitation in light of the Supreme Court’s decision in Union of India Vs Rajeev Bansal (2024) 469 ITR 46 (SC) & subsequent rulings in Deepak Steel & Power Ltd. Vs CBDT (CA No. 5177/2025) & ACIT Vs Nehal Rashid Shah (SLP Civil Diary No. 57209/2024). It was contended that for AY 2015-16, the relaxation under the Taxation & O...