Section 148 Notice Invalid Because TOLA Extension Did Not Apply

Bhushan Lal Pandita Vs Assessment Unit Income Tax Department (ITAT Delhi) Reassessment Notice Dated 31.03.2021 for AY 2015-16 Held Time-Barred: ITAT Delhi Quashes Proceedings The Delhi Bench of the ITAT allowed the assessee’s appeal and quashed the reassessment proceedings initiated under section 148 for AY 2015-16, holding the notice dated 31.03.2021 to be barred by limitation. Relying on the Supreme Court judgment in Union of India v. Rajeev Bansal (469 ITR 46), the Tribunal noted that the Revenue had conceded that for AY 2015-16, all reassessment notices issued on or after 01.04.2021 are ...