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Income Tax : The Tribunal held that the reassessment notice issued on 26.07.2022 was beyond the permissible timeline under the surviving limita...
Income Tax : Mumbai ITAT held that reassessment notice issued under Section 148 for AY 2015-16 on 31.07.2022 was barred by limitation under Sec...
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The Mumbai ITAT held that reassessment under Section 148 cannot be initiated after three years unless the alleged escaped income exceeds ₹50 lakh. Since the disputed amount was only ₹7.10 lakh, the reopening was quashed.
The ITAT Delhi held that reassessment notices issued after expiry of the surviving limitation period under the amended reassessment regime were invalid. The Tribunal quashed the reopening proceedings and related penalties for both assessment years.
The ITAT held that reassessment notices issued on 25.07.2022 were time-barred since the Revenue had only one surviving day left under the Supreme Court’s Rajeev Bansal limitation formula.
The case examined validity of a reassessment notice issued beyond statutory limits. The ITAT held the notice invalid as it exceeded the permissible time period. It reinforces strict compliance with limitation provisions.
The issue was whether reassessment notice issued without approval from the correct authority is valid. The tribunal held it invalid and quashed the assessment for lack of jurisdiction.
The Court held that reassessment proceedings must be initiated within the statutory time limit. It found the notice issued after the deadline to be invalid.
ITAT Mumbai quashes ₹1.64 Cr reassessment for faceless violation & time-barred notice u/s 148; holds jurisdictional defect fatal, TOLA cannot extend limitation.
The Tribunal held reassessment invalid as the alleged escaped income did not exceed ₹50 lakh required for extended limitation. It ruled that invoking extended time under Section 149 without satisfying this condition is illegal.
ITAT Mumbai deleted Section 69 addition on alleged on-money, holding third-party statements and unverified pen drive data lack evidentiary value without corroboration or cross-examination, upholding natural justice.
The notice issued after the permissible window calculated under TOLA and judicial rulings was held void. The case highlights strict adherence to limitation timelines.