Section 148A Proceedings Cannot Cure Invalid Old Reassessment Notice

ITO Vs Neem Chand (ITAT Delhi) AY 2015-16 Reopening After 01-04-2021 Is Dead on Arrival: TOLA Shield Not Available for AY 2015-16:- Delhi ITAT Applies Rajeev Bansal Logic Delhi ITAT ‘D’ Bench in ITO, Hisar vs Neem Chand (ITA No.2404/Del/2025, AY 2015-16, order dated 23-12-2025) dismissed the Revenue’s appeal and upheld the order of CIT(A) quashing the reassessment, holding that all notices u/s 148 issued on or after 01-04-2021 for AY 2015-16 under the old regime are bad in law and cannot be saved by TOLA. The case involved reopening based on bank deposits exceeding ₹10.42 crore. Origin...