Technical ITBA Errors Cannot Extend Limitation for Reassessment

ACIT Vs Kuldeep Kaur (ITAT Delhi) Notice Must Be Issued, Not Merely Generated- Notice u/s 148 Not Served Before Midnight- Service Failure Fatal – Technical Error in ITBA Cannot Extend Limitation: ITAT Says Reopening Barred by Limitation Despite AO’s Digital Signature Revenue appealed against order of CIT(A)-NFAC dated 28.10.2024 while Assessee filed cross objection challenging the validity of reassessment u/s 147 r.w.s.144B. Core legal issue was whether notice u/s 148 dated 31.03.2021 was issued within limitation. Assessee submitted that although the notice was digitally signed at 07:0...