ITAT Delhi quashes section 263 revision as reassessment itself held void ab initio

Pamela Bhardwaj Vs ITO (ITAT Delhi)

Attempt to Extend Assessment Time Through Section 148 Fails- Reassessment Without Expiry of 143(2) Window Held Invalid by ITAT

Assessee had filed a return declaring ₹1.96 lakh income & ₹2 lakh agricultural income, which was accepted originally. Subsequently, reassessment proceedings  u/s 147 were initiated citing unexplained cash deposits of ₹25.5 lakhs & property purchase worth ₹1.14 crore. The reassessment concluded by accepting the original return without making additions. PCIT later invoked Sec 263, te

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