https://www.taxtmi.com/caselaws?id=771509 ITAT Delhi held that reassessment notice u/s 148 was barred by limitation as it was dispatched on 01.04.2014, beyond the four-year period. The tribunal found that the assessee had fully disclosed all material facts during original assessment proceedings, and the AO had scrutinized all relevant information including depreciation claims, LPSE receipts, and capitalization. Citing SC precedent in Kelvinator case, the tribunal ruled that reassessment constituted mere change of opinion without fulfilling requisite pre-conditions. The reassessment order was declared void ab-initio for lack of jurisdiction and being time-barred. Decision favored assessee. en-us Wed, 16 Apr 2025 00:00:00 +0530 Tue, 27 May 2025 08:32:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771509 ITAT Delhi held that reassessment notice u/s 148 was barred by limitation as it was dispatched on 01.04.2014, beyond the four-year period. The tribunal found that the assessee had fully disclosed all material facts during original assessment proceedings, and the AO had scrutinized all relevant information including depreciation claims, LPSE receipts, and capitalization. Citing SC precedent in Kelvinator case, the tribunal ruled that reassessment constituted mere change of opinion without fulfilling requisite pre-conditions. The reassessment order was declared void ab-initio for lack of jurisdiction and being time-barred. Decision favored assessee. Case-Laws Income Tax Wed, 16 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771509