https://www.taxtmi.com/caselaws?id=775857 The ITAT Delhi held that the reopening of assessment under section 147 was barred by limitation as the notice under section 148 was issued beyond six years. Since no assessment under section 153A/143(3) was made earlier and no opportunity of hearing was given, Explanation 3 to section 153 did not apply. Consequently, the normal limitation period under section 149 governed the case. The appeal was allowed, affirming that the reopening notice was invalid due to being time-barred. en-us Tue, 29 Jul 2025 00:00:00 +0530 Fri, 01 Aug 2025 08:15:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775857 The ITAT Delhi held that the reopening of assessment under section 147 was barred by limitation as the notice under section 148 was issued beyond six years. Since no assessment under section 153A/143(3) was made earlier and no opportunity of hearing was given, Explanation 3 to section 153 did not apply. Consequently, the normal limitation period under section 149 governed the case. The appeal was allowed, affirming that the reopening notice was invalid due to being time-barred. Case-Laws Income Tax Tue, 29 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775857