https://www.taxtmi.com/caselaws?id=762803 ITAT Delhi held that limitation period for issuing notice u/s 143(2) relates to original return filing date, not rectified return date. When AO considered rectified return for assessment proceedings, the relevant limitation period remained tied to original return filing date. Following Delhi HC precedent in SMC COMTRADE LTD case, tribunal declared the notice u/s 143(2) invalid as it exceeded statutory time limit. Consequently, all subsequent assessment proceedings based on invalid notice were deemed bad in law. Assessment order was quashed and assessee's appeal was allowed. en-us Wed, 04 Dec 2024 00:00:00 +0530 Sat, 07 Dec 2024 08:14:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762803 ITAT Delhi held that limitation period for issuing notice u/s 143(2) relates to original return filing date, not rectified return date. When AO considered rectified return for assessment proceedings, the relevant limitation period remained tied to original return filing date. Following Delhi HC precedent in SMC COMTRADE LTD case, tribunal declared the notice u/s 143(2) invalid as it exceeded statutory time limit. Consequently, all subsequent assessment proceedings based on invalid notice were deemed bad in law. Assessment order was quashed and assessee's appeal was allowed. Case-Laws Income Tax Wed, 04 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762803