https://www.taxtmi.com/caselaws?id=767889 ITAT Kolkata allowed the assessee's appeal and quashed the reopening of assessment under Section 147. The notice under Section 148 was issued on 31.03.2021 but dispatched on 01.04.2021 at 3:28 AM, making it time-barred. For AY 2015-16, extended period under TOLA was not available from 01.04.2021. Additionally, reopening after four years from assessment under Section 143(3) violated the first proviso to Section 147, as no failure to disclose material information was established by the AO in recorded reasons. en-us Tue, 25 Mar 2025 00:00:00 +0530 Thu, 27 Mar 2025 08:36:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767889 ITAT Kolkata allowed the assessee's appeal and quashed the reopening of assessment under Section 147. The notice under Section 148 was issued on 31.03.2021 but dispatched on 01.04.2021 at 3:28 AM, making it time-barred. For AY 2015-16, extended period under TOLA was not available from 01.04.2021. Additionally, reopening after four years from assessment under Section 143(3) violated the first proviso to Section 147, as no failure to disclose material information was established by the AO in recorded reasons. Case-Laws Income Tax Tue, 25 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767889