https://www.taxtmi.com/caselaws?id=764506 The ITAT Delhi quashed a reassessment order under section 147 for AY 2010-11 as it was barred by limitation. The notice under section 148 was issued after four years from the end of the relevant assessment year without any allegation by the AO that income escapement was due to the assessee's failure to disclose material facts fully and truly. Following the precedent in Duli Chand Singania case, the tribunal held that reopening after four years of original assessment under section 143(3) violated the first proviso to section 147. The reassessment was deemed bad in law and decided in favor of the assessee. en-us Thu, 09 Jan 2025 00:00:00 +0530 Sat, 11 Jan 2025 08:46:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764506 The ITAT Delhi quashed a reassessment order under section 147 for AY 2010-11 as it was barred by limitation. The notice under section 148 was issued after four years from the end of the relevant assessment year without any allegation by the AO that income escapement was due to the assessee's failure to disclose material facts fully and truly. Following the precedent in Duli Chand Singania case, the tribunal held that reopening after four years of original assessment under section 143(3) violated the first proviso to section 147. The reassessment was deemed bad in law and decided in favor of the assessee. Case-Laws Income Tax Thu, 09 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764506