https://www.taxtmi.com/caselaws?id=767534 The ITAT Delhi allowed the assessee's appeal against reopening of assessment u/s 147 for AY 2015-16. The tribunal held that notices u/s 148 issued on 30/06/2021 and 25/07/2022 were both barred by limitation. Revenue's Additional Solicitor General had categorically stated before SC in Rajiv Bansal case that all notices for AY 2015-16 issued on or after 1st April 2021 would be dropped, but no such action was taken. The six-year limitation period expired on 31st March 2022, making the notice dated 25/07/2022 time-barred. SC held TOLA was not applicable for AY 2015-16, confirming limitation under old provisions of section 149. en-us Wed, 12 Feb 2025 00:00:00 +0530 Thu, 20 Mar 2025 08:21:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767534 The ITAT Delhi allowed the assessee's appeal against reopening of assessment u/s 147 for AY 2015-16. The tribunal held that notices u/s 148 issued on 30/06/2021 and 25/07/2022 were both barred by limitation. Revenue's Additional Solicitor General had categorically stated before SC in Rajiv Bansal case that all notices for AY 2015-16 issued on or after 1st April 2021 would be dropped, but no such action was taken. The six-year limitation period expired on 31st March 2022, making the notice dated 25/07/2022 time-barred. SC held TOLA was not applicable for AY 2015-16, confirming limitation under old provisions of section 149. Case-Laws Income Tax Wed, 12 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767534