Reopening Beyond 3 Years Below ₹50 Lakh Quashed

Manishaben Dilip Vankar Vs DCIT (ITAT Ahmedabad) Reassessment Beyond 3 Years Below ₹50 Lakh Escapement Quashed: Wrong Sanction, Wrong Jurisdiction—148 Notice Held Invalid Post-2021 Regime The Ahmedabad SMC Bench of the ITAT, in Manishaben Dilip Vankar vs DCIT (ITA No. 691/Ahd/2025, AY 2016-17), quashed the reassessment proceedings in entirety by holding that the reopening u/s 147 was barred by limitation and suffered from invalid sanction under the post-2021 reassessment regime. The Assessee’s original return was processed u/s 143(1) and later reopened based on INSIGHT Portal information...