ITAT Delhi Annuls Reopening Email Notice as Time-Barred Under TOLA

ITO Vs Kolahai Infotech Private Limited (ITAT Delhi) AY 2015-16 Reassessment Time-Barred—Revenue’s Own Concession in Rajeev Bansal Binding; 148 Notice Invalid & Assessment Annulled  The Revenue appealed against the CIT(A)’s order dated 25-03-2025 annulling the reassessment for AY 2015-16. The Assessee, a private limited company, had originally been assessed u/s 143(3) in 2017. A notice u/s 148 (old regime) was issued on 22-04-2021, later treated as a 148A(b) notice pursuant to the Supreme Court’s ruling in Ashish Agarwal. The AO passed a 148A(d) order on 28-07-2022, issued a fresh...