Delhi HC Rules Reassessment Proceedings Beyond Limitation Invalid

Manisha Agarwal Vs ITO (Delhi High Court)

The Delhi High Court in Manisha Agarwal vs ITO examined the validity of reassessment proceedings initiated for Assessment Year (AY) 2014–15. The petitioner challenged multiple actions of the Income Tax Department, including the notice dated 08.06.2021 (deemed notice under Section 148A(b)), the order dated 25.07.2022 under Section 148A(d), and the notice under Section 148 issued on the same date, on grounds of limitation and procedural irregularities.

The petitioner argued that although the initial notice under Section 148

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