Rajeev Bansal Strikes Again – Time-Barred Reopening & Entire Capital-Gain Addition Quashed

Shyam Gopal Vs DCIT (ITAT Delhi) ITAT Delhi allowed the assessee’s appeal for AY 2013-14 in Shyam Gopal, quashing the entire reassessment and ₹5.48 crore capital-gain addition purely on limitation, without going into merits. The Tribunal held that the notice u/s 148 dated 20-07-2022 (issued post-Ashish Agarwal) was hopelessly time-barred when tested against the law laid down by the Supreme Court in Union of India v. Rajeev Bansal. Applying the exact timeline computation (TOLA extension, deemed 148A(b) notice, response period and surviving days), the Bench found that the last permissible da...