ITAT Mumbai Quashed Reassessment Notice for Being Issued Beyond Limitation Period

Aditya Birla Sun Life Insurance Co. Limited Vs DCIT (ITAT Mumbai)

These cross appeals by the assessee and the Revenue arose from a consolidated order of the Commissioner of Income Tax (Appeals) for Assessment Years (AYs) 2015–16 and 2016–17. For both years, the central issue before the Tribunal was the validity of reassessment proceedings initiated under Section 148 of the Income Tax Act, 1961, following the amended reassessment regime introduced by the Finance Act, 2021 and interpreted by subsequent Supreme Court and High Court rulings.

For AY 2015–16, the assessee ha

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