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:

1. Reopening u/s 148 was TIME-BARRED

• Notice u/s 148 issued on 30.07.2022.
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