Reopening Beyond limitation – Mechanical Approval Fatal – Entire Batch Collapses

DCIT Vs Proform Interiors Pvt. Ltd (ITAT Delhi) ITAT Delhi upheld CIT(A) and dismissed Revenue’s appeal for AY 2012-13, holding reopening time-barred despite search in Feb-2022. Applying the first proviso to s.149(1)(b) and the Supreme Court ruling in Rajeev Bansal, the Tribunal held that for AYs prior to 2021-22, limitation must be tested under the old regime. On that yardstick, AY 2012-13 was already dead; the extended 10-year window under the new law cannot revive a barred year. For the remaining years AYs 2013-14 to 2022-23, the Tribunal struck down assessments on an even stronger ground...