ITAT Sets Aside Post-April 2021 Reassessment Notice as Invalid Under TOLA

Aarti Bansal Vs ITO (ITAT Delhi) The appeal concerns Assessment Year 2014-15 and challenges the reassessment proceedings initiated under Sections 147/148 of the Income Tax Act, 1961. The assessee contested the reassessment on multiple grounds, primarily arguing that the notice issued under Section 148 dated 22.07.2022 was barred by limitation and that all consequential reassessment actions were therefore void ab initio. The assessee further contended that the AO failed to comply with procedural requirements under Sections 143(2), 148A, and 149(1), and that the additions made under Section 69C ...