https://www.taxtmi.com/caselaws?id=780113 ITAT (Del) held the reassessment proceedings invalid and allowed the appeal. The notice under section 148 issued 30/07/2022 was time-barred; the earlier 30/06/2021 notice could not be validated by TOLA for AY 2015-16. The 148A(b) notice dated 27/05/2022 was also defective because the AO failed to supply the underlying information/material as directed by the SC, vitiating reopening under s.147. Addition under s.69A was unsubstantiated, based on preliminary FIR and assumptions without cash-trail or corroborative evidence, and therefore unsustainable. en-us Wed, 15 Oct 2025 00:00:00 +0530 Sat, 18 Oct 2025 09:08:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780113 ITAT (Del) held the reassessment proceedings invalid and allowed the appeal. The notice under section 148 issued 30/07/2022 was time-barred; the earlier 30/06/2021 notice could not be validated by TOLA for AY 2015-16. The 148A(b) notice dated 27/05/2022 was also defective because the AO failed to supply the underlying information/material as directed by the SC, vitiating reopening under s.147. Addition under s.69A was unsubstantiated, based on preliminary FIR and assumptions without cash-trail or corroborative evidence, and therefore unsustainable. Case-Laws Income Tax Wed, 15 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780113