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Audit Objection Can’t Reopen Past Assessment, U/s 148 Notice Quashed
Case Law Details
- Case Name
- ACIT Vs Chinraj Shanthi (ITAT Chennai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All ITAT, ITAT Chennai
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ACIT Vs Chinraj Shanthi (ITAT Chennai)
From Audit Note to Dead Notice: 148 Notice Struck Down by ITAT- Audit Objection Can’t Reopen Past: Change of Opinion Is Not ‘Reason to Believe’: Reassessment Quashed
In ACIT, Central Circle (I/c), Salem Vs. Chinraj Shanthi, ITA No.2037/Chny/2025 & CO No.81/Chny/2025, AY 2012-13, order dated 31.12.2025, Chennai ITAT dismissed Revenue’s appeal & upheld quashing of reassessment initiated u/s 147 r.w.s. 148 beyond four years. Original assessment was completed u/s 143(3) on 14.11.2014. Subsequently, AO reopened assessment on 31.03.2019 alleging...

