Reassessment Notice for AY 2015-16 Quashed as Time-Barred Under Section 149

Elegance Reality Vs ACIT (ITAT Ahmedabad)

The appeal was filed by the assessee against the order dated 25.11.2025 passed by the Commissioner of Income Tax (Appeals), NFAC, Delhi, for Assessment Year (A.Y.) 2015-16. The primary challenge was to the validity of reopening of assessment under Sections 147/148 of the Income Tax Act, 1961, on the ground of limitation.

Originally, notice under Section 148 was issued on 11.06.2021 within the extended time period under the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA). Following the Supreme Courtâ€

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