ITAT Remands Case to CIT(A) After Incorrect Return Filing Date Led to Erroneous Dismissal on Limitation Grounds

ITO Vs Emerlad Mining Private Limited (ITAT Cuttack) In ITO vs. Emerald Mining Private Limited, the ITAT Cuttack reviewed an appeal against a CIT(A) decision dated March 26, 2024, which had quashed an assessment due to an alleged delay in issuing a notice under Section 143(2) of the Income Tax Act. The CIT(A) had incorrectly determined that the notice was time-barred based on a misreported filing date of November 25, 2015, while the actual filing date was November 27, 2016. This error led to the appeal being allowed on the grounds of limitation, without addressing the merits of the case. The I...