In Sanjeev Kumar Aggarwal v.
Deputy Commissioner of Income Tax, Circle-52(1), Delhi (ITAT Delhi, order
dated 09 January 2026), the Delhi Bench of the Income Tax Appellate Tribunal
examined the validity of reassessment proceedings initiated for Assessment
Year 2015-16 under Sections 147 and 148 of the Income-tax Act, 1961.
The reassessment was initiated
pursuant to a notice issued under Section 148 on 26 July 2022, following
the procedure prescribed under the new reassessment regime introduced by the
Finance Act, 2021 and the Supreme Court decision in Union of India v. Ashish
Agarwal. The assessment was completed on 25 May 2023. The assessee
challenged the proceedings on the ground that the notice under Section 148 was
barred by limitation.
The Tribunal noted that, as per
the amended provisions of Section 149 and the authoritative judgment of
the Supreme Court in Union of India v. Rajeev Bansal,
reassessment notices for AY 2015-16 could not be issued after 31 March 2022,
as the extended limitation under the Taxation and Other Laws (Relaxation and
Amendment of Certain Provisions) Act, 2020 (TOLA) was not applicable to that
assessment year. The Revenue had itself conceded before the Supreme Court that
all notices issued on or after 1 April 2021 for AY 2015-16 were liable to be
dropped.
The Tribunal further relied on
the decisions of the Delhi High Court in Sarthak Gupta v. ITO and IBIBO
Group Pvt. Ltd. v. ACIT, wherein reassessment notices issued on
identical facts and on the same date were held to be time-barred. Applying
these binding precedents, the Tribunal held that the notice dated 26 July 2022
was clearly beyond the permissible period of limitation.
Accordingly, the Tribunal
concluded that the reassessment proceedings and the consequent assessment order
were without jurisdiction and barred by limitation, set aside the
assessment order, and allowed the assessee’s appeal.
Source Link- https://itat.gov.in/public/files/upload/1767939712-uYrARe-1-TO.pdf
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