https://www.taxtmi.com/caselaws?id=774746 The ITAT Delhi held that a reopening assessment under Section 147 was invalid due to procedural failures. The notice under Section 148 was issued on 10.04.2018, which exceeded the six-year limitation period ending 31.03.2018. Citing RK Upadhyaya v. Shanabhai P. Patel, the tribunal ruled that while actual issuance satisfies notice requirements, the belated service invalidated the entire assessment. The tribunal directed deletion of all additions and allowed the assessee's appeal, emphasizing that procedural non-compliance renders the assessment legally unsustainable. en-us Fri, 06 Jun 2025 00:00:00 +0530 Mon, 14 Jul 2025 08:36:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774746 The ITAT Delhi held that a reopening assessment under Section 147 was invalid due to procedural failures. The notice under Section 148 was issued on 10.04.2018, which exceeded the six-year limitation period ending 31.03.2018. Citing RK Upadhyaya v. Shanabhai P. Patel, the tribunal ruled that while actual issuance satisfies notice requirements, the belated service invalidated the entire assessment. The tribunal directed deletion of all additions and allowed the assessee's appeal, emphasizing that procedural non-compliance renders the assessment legally unsustainable. Case-Laws Income Tax Fri, 06 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774746