Time-Barred Notice, No Evidence, MAT Higher – ITAT Quashes Reopening & Wipes Out ₹25 Cr Addition

Dharampal Satyapal Ltd. Vs ACIT (ITAT Delhi) Assessee challenged reopening u/s 147 and an addition of ₹25.21 crore u/s 69A alleging unaccounted cash from “VAT evasion” by its consignee agents in Gujarat based on an FIR forwarded by the Investigation Wing. Tribunal not only examined merits but first struck down the reassessment itself on multiple strong legal grounds: Reopening u/s 148 was TIME-BARRED Notice u/s 148 issued on 30.07.2022. For AY 2015-16, 6-year limit expired on 31.03.2022. As per first proviso to section 149(1), no notice can be issued after 6 years under the new regim...