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    <title>2026 (5) TMI 1626 - ITAT DELHI</title>
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    <description>Reassessment proceedings under the old regime were found unsustainable where the notice under section 148 was dated 31.03.2021 but was communicated to the assessee only on 16.04.2021, and no material was produced to dispute that timeline. The Tribunal applied the principle that mere generation of a notice on the ITBA portal does not validate reassessment once service and communication occur after the cut-off date, and the procedure under section 148A was not followed. On that basis, the reassessment was vitiated, the additional ground was allowed, and the reassessment order was quashed in favour of the assessee.</description>
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      <title>2026 (5) TMI 1626 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=792424</link>
      <description>Reassessment proceedings under the old regime were found unsustainable where the notice under section 148 was dated 31.03.2021 but was communicated to the assessee only on 16.04.2021, and no material was produced to dispute that timeline. The Tribunal applied the principle that mere generation of a notice on the ITBA portal does not validate reassessment once service and communication occur after the cut-off date, and the procedure under section 148A was not followed. On that basis, the reassessment was vitiated, the additional ground was allowed, and the reassessment order was quashed in favour of the assessee.</description>
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