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ITAT Delhi held that satisfaction note recorded before initiation of the proceedings u/s 153C of the Income Tax Act is not a valid satisfaction. Accordingly, proceedings u/s. 153C of the Income Tax Act is quashed since based on invalid satisfaction.
The Tribunal held that reopening AY 2012–13 after a post-2021 search was barred by limitation. Applying Supreme Court guidance, it ruled that older limitation periods protect concluded assessments from retrospective reopening.
The issue concerned reopening based on notices never validly served on the assessee. The Tribunal held that defective service of notices strikes at the root of jurisdiction and invalidates the reassessment.
ITAT Hyderabad held that limitation for issuing notice under section 148 of the Income Tax Act would be only 3 years from the end of the assessment year since material suggesting escapement is less than Rs. 50 Lakhs. Hence, notice issued u/s. 148 is beyond period of limitation of three years hence quashed.
The Tribunal held that where reassessment is based solely on search material found during a third-party search, proceedings must be initiated under section 153C. Reopening under section 147 was held to be without jurisdiction and quashed.
Reassessment was struck down as no satisfaction note by the searched person’s AO was shown. The ruling reiterates that limitation cannot be bypassed through procedural shortcuts.
The issue was whether a Section 148 notice for AY 2015-16 issued in August 2024 was time-barred. The Court held it exceeded the ten-year limit and quashed the proceedings.
The issue was whether reassessment notices issued after the extended period under TOLA were valid. The Tribunal held that post–Rajeev Bansal, notices beyond the surviving limitation are time-barred and void.
The case examined whether procedural compliance under section 148A could revive a time-barred reopening. It was held that procedural steps cannot resurrect jurisdiction lost by efflux of time.
The Tribunal ruled that reopening beyond six years is invalid without a recorded satisfaction of undisclosed assets exceeding ₹50 lakh. The takeaway is strict compliance with the fourth proviso to section 153A is mandatory.
