Mumbai ITAT Quashes AY 2015-16 Reassessment as Time-Barred – Revenue’s Own Concession in Rajeev Bansal Proves Fatal

Vinod Shyamsunder Pasari Vs DCIT (ITAT Mumbai) The Mumbai ITAT quashed reassessment proceedings for AY 2015-16 holding that the notice issued u/s 148 on 31.07.2022 was barred by limitation under section 149. The Tribunal noted that though the original notice dated 21.06.2021 was treated as a deemed notice u/s 148A(b) pursuant to the Supreme Court ruling in Ashish Agrawal, the fresh notice issued on 31.07.2022 could not survive since for AY 2015-16 the limitation had already expired on 31.03.2022. The Tribunal heavily relied upon the Revenue’s own concession recorded by the Supreme Court in U...