Reassessment Quashed Because Notice Was Issued Beyond Limitation Period

Anita Tomar Vs ITO (ITAT Delhi) The Delhi Bench of the Income Tax Appellate Tribunal considered an appeal for Assessment Year 2016–17 challenging reassessment proceedings initiated under sections 147 read with 144 of the Income-tax Act, 1961. The primary issue before the Tribunal was the validity of the reopening itself. It was noted that the notice under section 148 had been issued on 30 March 2023, which was beyond three years from the end of the relevant assessment year. During the hearing, the Revenue could not dispute that, under section 149(1)(b) of the Act, reopening after three years...