Section 148 Reopening on Stale Search Material Invalid: ITAT Kolkata

Advertisement DCIT Vs Ajay Jalan (ITAT Kolkata) The Revenue appealed against the order of the Commissioner of Income Tax (Appeals) relating to Assessment Year 2019-20, wherein the reassessment initiated under Sections 147 and 148 and the addition made under Section 69A were set aside. The original return had been filed under Section 139(1) and processed under Section 143(1). Following a search under Section 132 in the case of the Jalan Group, the assessee’s case was assessed under Section 143(3) read with Section 153A on 28.03.2022. Subsequently, a notice under Section 148 dated 06.04...