Reassessment Quashed as Year of Search Cannot Be Reopened Under Section 148

Arjun Singh Sahi Vs DCIT/ACIT (ITAT Dehradun)

The appeal for Assessment Year 2017-18 arose from reassessment proceedings initiated under Sections 147 and 148 of the Income-tax Act, 1961. The assessee, an individual, was apprehended by police authorities on 13.01.2017 with cash of Rs.10 lakhs, which was seized on the same date. He filed his original return under Section 139(1) on 28.07.2017 and a revised return under Section 139(5) on 08.09.2017. The Assessing Officer (AO) subsequently issued a notice under Section 153A on 16.10.2018, which was dropped on 05.07.2019. Thereafter, the

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