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of <h1>Petition disposed; Assessing Officer directed to honor limitation-period assurances for AY 2015-16 per binding precedent</h1> <h3>Shreyansh Mehta Versus Income Tax Officer, Ward 2 (1), Udaipur, Central Board Of Direct Taxes, Department Of Revenue, Ministry Of Finance, Government Of India, New Delhi</h3> High Court disposed of the petition and directed the Assessing Officer to decide the proceedings in accordance with law, taking into consideration the ... Reopening of assessment - limitation period for the Assessment Year 2015-16 - scope of TOLA - HELD THAT:- Respondents is unable to refute the aforesaid submissions and requests that the petition be disposed of with directions to the concerned Assessing Officer to take into consideration the assurance given by the respondents in the case of Rajeev Bansal’s case [2024 (10) TMI 264 - SUPREME COURT (LB)] of not carrying forward the notices, that have exceeded the limitation period for the Assessment Year 2015-16. Present petition is disposed of with the directions to the Assessing Officer to decide the proceedings in accordance with law, taking into consideration the ratio laid down in Rajeev Bansal’s case. Petitioner relied on Union of India & Ors. v. Rajeev Bansal ((2024) 469 ITR 46), submitting the limitation period for Assessment Year 2015-16 had expired and that in Rajeev Bansal the respondents conceded to 'drop the proceedings for Assessment Year 2015-16.' Notice under Section 148, Income Tax Act, was issued on 27.07.2022, after expiry of the limitation period. Respondent counsel did not refute these submissions and requested directions that the Assessing Officer take into consideration the assurance in Rajeev Bansal of 'not carrying forward the notices, that have exceeded the limitation period for the Assessment Year 2015-16.' The court directed the Assessing Officer to 'decide the proceedings in accordance with law, taking into consideration the ratio laid down in Rajeev Bansal's case (supra) and the submissions made by learned counsel for the respondents.' All pending applications, if any, were disposed of.
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