Reassessment Quashed Due to Invalid Section 148 Notice

Shivaaditiya Jems and Jewellery Pvt. Ltd vs. ITO (ITAT Delhi) Dispatch Date Decides Fate: Signed on 31 March, Sent After 1 April: Email & Speed Post After 1 April Sink Old-Regime Notice-Reassessment Collapses Delhi ITAT quashed reassessment for AY 2017-18 holding that notice dated 31.03.2021 u/s 148, though digitally signed on 31.03.2021, was actually dispatched by speed post on 06.04.2021 & emailed on 02.04.2021 and hence deemed to be issued after 01.04.2021. In Shivaaditiya Jems and Jewellery Pvt. Ltd vs. ITO, ITA Nos. 5661 & 4857/Del/2024, Tribunal relied on RTI replies of AO ad...