Old U/s 148 Notice Converted Later Still Time-Barred for AY 2015-16

Genpact Servies LLC Vs ACIT (ITAT Delhi) AY 2015-16 Reopening After 01.04.2021 Is Dead on Arrival- TOLA Can’t Save AY 2015-16 In Genpact Services LLC Vs. ACIT, ITA No.3480/Del/2025, AY 2015-16, order dated 31.12.2025, Delhi ITAT quashed reassessment proceedings as time-barred & allowed Assessee’s appeal. Assessee was issued notice u/s 148 on 08.04.2021 under old regime, which was later sought to be converted into new regime proceedings pursuant to SC decision in UOI Vs. Ashish Agarwal. Subsequently, notice u/s 148A(b) was issued on 01.06.2022, followed by order u/s 148A(d) & fresh ...