Reassessment for AY 2015-16 Time-Barred – ITAT Quashes Entire Penny Stock Addition

Sandip Sadanand Narkar Vs ITO (ITAT Mumbai) The Mumbai ITAT quashed the reassessment proceedings for AY 2015–16, holding that the notice issued u/s 148 after 01.04.2021 was time-barred under the amended Section 149, and hence the entire addition on alleged penny stock transactions was invalid. The AO had reopened the case based on penny stock information (Kabra Drugs Ltd.) and treated the entire sale proceeds of ₹49.47 lakh as unexplained u/s 68, alleging accommodation entries. The CIT(A) upheld both reopening and addition. However, the ITAT held: As per the Supreme Court ruling in Rajeev...