New Reassessment Law Overrides Old Limitation Extensions

Pooja Prabhakar Vs ITO (ITAT Chennai) Reassessment Time-Barred Under New Law: ITAT Chennai Quashes s.148 Notice Dated 31.07.2022 for AY 2014-15 Chennai ITAT ‘D’ Bench, in Pooja Prabhakar vs. ITO  (ITA No.3045/Chny/2025, AY 2014-15, order dated 26.12.2025), allowed the assessee’s appeal by condoning 178 days’ delay, admitting additional legal grounds, and quashing the reassessment u/s 147 r.w.s. 144 as barred by limitation and void ab initio. The assessment was reopened based on alleged bank credits of ₹1.99 crore and investment in residential property of ₹3.81 crore. Proceedings w...