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The Court held that Section 148 notices dated 31 March 2021 but issued after that date could not be treated as issued within the old limitation period. The ruling applies the amended reassessment framework and the Supreme Court’s directions in similar cases.
The Tribunal held that notices under section 153C issued without independent satisfaction by the AO are invalid, quashing the consequent assessments for AY 2018-19 to 2020-21.
Tribunal clarified that mere generation or digital signing on ITBA does not mean a notice is issued. Proper dispatch to the assessee’s email or portal before the statutory deadline is required for validity.
Aseem Sehgal Vs ITO (ITAT Delhi) The appeals concern assessment years 2015–16 to 2017–18 and arise from reassessment orders issued under Sections 147 and 144B of the Income-tax Act. The sole issue examined by the Tribunal is whether the Assessing Officer was justified in framing reassessment under the pre-April 2021 provisions despite issuing the notice […]
The Tribunal rejected the Revenue’s argument that TOLA extended the time for issuing notice, holding that for A.Y. 2015-16 the limitation expired on 31.03.2019. Consequently, the 21.04.2021 notice lacked legal authority. Key takeaway: TOLA does not revive time-barred assessments.
The Tribunal held that a reopening made after three years is void when approval is granted by the PCIT instead of the PCCIT/CCIT. The entire reassessment and related disallowance were struck down.
Tribunal invalidated the reassessment because the Assessing Officer failed to obtain mandatory approval from the specified authority under Section 151(ii), rendering the Section 148 notice void.
Bombay High Court held that reopening of assessment proceedings on the basis of change of mind/opinion and also on non-application of mind is liable to be quashed and set aside. Accordingly, impugned notices and order quashed.
The tribunal ruled that reassessment notices issued after April 2021 for AY 2015-16 are invalid, as they fall outside TOLA provisions and are time-barred.
The case examines whether a Section 148 notice issued after the extended limitation period was invalid. Key takeaway: approval beyond three years required the higher authority under Section 151(ii), making the notice vulnerable.
