Reopening for AY 2015-16 After 01.04.2021 Invalid; Consequential Section 263 Order Also Quashed

A.B. Motors Pvt. Ltd. Vs DCIT (ITAT Chandigarh) ITAT Chandigarh: Reopening for AY 2015-16 After 01.04.2021 Invalid; Consequential Section 263 Order Also Quashed The Income Tax Appellate Tribunal allowed both appeals of the assessee for AY 2015-16, holding that the reopening under section 147 pursuant to a notice under section 148 issued after 01.04.2021 was time-barred, and consequently, the revisionary order under section 263 could not survive. On the quantum appeal, the Tribunal noted that the notice under section 148 dated 12.04.2021 sought to reopen AY 2015-16 based on information from the...