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Reopening Beyond Four Years Without Alleging Assessee’s Failure Is Void
Case Law Details
- Case Name
- ACIT Vs Make My Trip (India) P. Ltd. (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 10/11/2025
- Courts
- All ITAT, ITAT Delhi
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ACIT Vs Make My Trip (India) P. Ltd. (ITAT Delhi)
Reopening Beyond Four Years Without Alleging Assessee’s Failure Is Void; Verbatim Reasons, No New Material: ITAT Invalidates 147 Notices
Delhi Tribunal quashed the reassessments for AY 2007-08 & AY 2008-09 in the case of Make My Trip (India) Pvt. Ltd., holding that the reopening was beyond four years & failed to satisfy the mandatory jurisdictional requirement under the first proviso to section 147. Assessee had fully disclosed all material facts in the original assessment, including the reimbursement of Rs.3.60 cror...
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