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Reassessment Notices Quashed: Time-Bar under Rajeev Bansal & Invalid Section 151 Approval
Case Law Details
- Case Name
- ITO Vs LNG Agricom Private Limited (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All ITAT, ITAT Delhi
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ITO Vs LNG Agricom Private Limited (ITAT Delhi)
Delhi ITAT examined jurisdictional defects in reassessment proceedings for AYs 2015-16 & 2016-17. In CO No.219 (AY 2015-16), Assessee argued that notice u/s 148 dated 30.06.2021 was barred by limitation u/s 149, relying on Supreme Court ruling in UOI Vs Rajeev Bansal, which held that reassessment notices must fall within surviving six-year period even after exclusion under Ashish Agarwal mechanism. Tribunal held that notice dated 30.06.2021 for AY 2015-16 exceeded permissible six-year window & was therefore time-barred; consequent reasse...
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