Time-Barred Reassessment Notices Quashed: Limitation Period Enforced

Seema Goel Vs CIT(A) (ITAT Delhi) Strikes Down July 2022 Notices for AYs 2015-16 & 2016-17- No Escape from Limitation Assessee, an individual, filed returns declaring incomes of ₹27.83 lakh for AY 2015-16 & ₹45.68 lakh for AY 2016-17. Reassessment proceedings were initiated u/s 147 by issue of notice u/s 148, which after the decision of SC in Union of India Vs Ashish Agarwal were deemed as notices u/s 148A(b). Orders u/s 148A(d) were thereafter passed, followed by notices u/s 148 in July 2022. AO completed reassessments making substantive & protective additions aggregating ₹5...