Section 148 Reopening Notice Issued Late is Invalid: ITAT Delhi

Global Emerging Markets India Limited Vs Assessment Unit (ITAT Delhi) Reopening Time-Barred Post Rajeev Bansal: ITAT Quashes Section 148 Notice Issued Beyond Limitation The Delhi Bench “B” of the ITAT, in Global Emerging Markets India Ltd. v. NFAC (AY 2013-14), quashed the reassessment proceedings holding that the notice issued under section 148 on 28.06.2022 was barred by limitation, even after applying the relaxation framework laid down in Ashish Agarwal and clarified by the Supreme Court in Rajeev Bansal. The Tribunal analysed the entire statutory timeline in detail, noting that the ori...