Delhi HC Quashes Reassessment as Second Section 148 Notice was Time-Barred

Pratishtha Garg Vs ACIT (Delhi High Court) The Delhi High Court, in the case of Pratishtha Garg Vs ACIT, addressed the validity of a second reassessment proceeding initiated against the assessee for the Assessment Year (AY) 2016-17. The core issue involved the continuity of parallel reassessment notices despite the initial one being dropped. The sequence of events began with the AO issuing a first notice under Section 148 on June 23, 2021, seeking to reopen the assessment. This notice, along with others issued nationwide using the pre-March 31, 2021, regime, was challenged. Following the Supre...