ITAT Quashes Reassessment: Revenue’s Appeal Fails Because 148 Notice Invalidity was Unchallenged

ITO Vs Virat Promoters Private Limited (ITAT Delhi)

Legal Ground Unchallenged = Automatic Knockout ITAT Dismisses Appeal Instantly

If the reopening notice u/s 148 is held invalid & Revenue does not challenge that finding, the reassessment is dead & all additions automatically collapse without going into merits.

Assessee had originally filed its return for A.Y. 2013-14 declaring a small loss. Years later, AO reopened the case u/s 147 & , following the procedure laid down in the Supreme Cour

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