Assessment Order Quashed due to Invalid Service U/s 282 & Limitation

Zeliant Corp Vs ITO (ITAT Delhi)

In this case, the assessee challenged the validity of the assessment framed u/s 144 wherein cash deposits were treated as unexplained money u/s 69A r.w.s. 115BBE. The primary contention before ITAT was that the assessment order itself was void ab initio as notices & assessment order were never validly served within limitation as per procedure prescribed u/s 282 r.w.r. Rule 127.

The AO had made addition of ₹83,50,900/- alleging unexplained dep

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