ITAT Quashes Reassessment: Revenue’s Appeal Fails Because 148 Notice Invalidity was Unchallenged

ITO Vs Virat Promoters Private Limited (ITAT Delhi) Legal Ground Unchallenged = Automatic Knockout ITAT Dismisses Appeal Instantly If the reopening notice u/s 148 is held invalid & Revenue does not challenge that finding, the reassessment is dead & all additions automatically collapse without going into merits. Assessee had originally filed its return for A.Y. 2013-14 declaring a small loss. Years later, AO reopened the case u/s 147 & , following the procedure laid down in the Supreme Court decision in Ashish Agarwal, passed an order of reassessment u/s 147 r.w.s. 144B, making two ...