Reassessment Notice u/s 148 Quashed Due to Issuance Beyond Limitation Period

Harish Kumar Vs NFAC (ITAT Delhi) Brief facts:  The Assessee filed the return of income for AY 2015–16 on 17.09.2015, declaring a total income of ₹11,86,80,770/-. Based on information flagged under the Risk Management Strategy (RMS) as formulated by the Central Board of Direct Taxes (CBDT), the case was reopened, and notice under section 148 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) was issued on 23.06.2021 after obtaining prior approval from the Principal Commissioner of Income Tax, Delhi-4. The assessment was completed under section 147 read with sec...