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The Tribunal ruled that the Assessing Officer could issue a reassessment notice only within the balance days available after excluding the stayed period. Issuance beyond that surviving window renders the notice time-barred.
The assessment based on a second notice issued in July 2022 was quashed as time-barred. Once limitation had expired, subsequent notices could not revive reassessment jurisdiction.
The Tribunal ruled that repeated reopening cannot survive where statutory timelines are breached. A reassessment initiated beyond the permissible surviving period was quashed in entirety.
The Tribunal held that reassessment proceedings initiated after the statutory limitation period were invalid. Following the Supreme Courts ruling on reassessment timelines, the entire reopening and resulting additions were quashed.
Addition of ₹2.28 crore made as long-term capital gains in the hands of the assessee society was deleted in full as amount paid by a developer directly to individual members of a co-operative housing society pursuant to redevelopment cannot be taxed as capital gains in the hands of the society, particularly when the society itself never received the amount.
The issue was whether a reassessment notice issued after 31.03.2021 for AY 2014-15 was within limitation. ITAT held the notice time-barred in light of the Supreme Court’s Rajeev Bansal ruling and quashed the entire reassessment.
It was ruled that a reassessment notice issued after expiry of the extended limitation is void. The takeaway is that delayed action under the new reassessment regime is fatal.
ITAT held that Section 153C cannot be invoked where the satisfaction/hand-over date is after 01.04.2021, quashing multiple assessments framed thereafter. The ruling follows the Madras High Court and reinforces Section 153C(3)’s statutory bar.
The tribunal held that the reassessment notice issued by relying on COVID-era extensions was invalid due to procedural lapses. As a result, the entire reassessment and addition were set aside.
With the reassessment notice quashed, the consequential assessment order and demand were automatically annulled. The ruling highlights that taxpayers cannot be burdened where initiation itself is unlawful.
