2026 (1) TMI 922

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....ssessment year 2015-16, wherein learned CIT(A) has partly allowed assessee's appeal. 2. Brief facts state that the assessee was engaged in the business of trading in shares and securities. The assessee filed original return of income for A.Y. 2015-16 on 11.09.2015, declaring total income of Rs. 24,78,460/-. An information was received from DGIT (Inv.), Mumbai through the Income-tax Business Application regarding coordinated and premeditated trading on the Mumbai Stock Exchange by engaging in reversal trades in illiquid stock options resulting in non-genuine business loss/gains to the beneficiary assessee's, to which the present assessee was a party to such manipulation. It was noticed from the data available under Project Falcon on the I....

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....the referred decision dated 03.10.2024 passed by Hon'ble Supreme Court in Union of India & Ors. vs. Rajeev Bansal [2024] 167 taxmann.com 70 (SC). 7. The instant case relates to A.Y. 2015-16. Assessing Officer initially issued notice dated 28.06.2021 u/s. 148 of the Act. The Finance Act, 2021 substituted section 147 to 151 of the Act w.e.f. 01.04.2021 and sections 147 to 151 of the old law ceased to operate from 01.04.2021. The Apex Court in Rajeev Bansal (supra) specifically observed that after 01.04.2021, any reference to the Income Tax Act means the Income Tax Act as amended by Finance Act, 2021 and held that the time limit prescribed for issuing reassessment notice u/s. 149 operate retrospectively for three years for all situation and....

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....3) (4) (5) 2013-2014 31.03.2017 TOLA not applicable 31.03.2020 30.06.2021 2014-2015 31.03.2018 TOLA not applicable 31.03.2021 30.06.2021 2015-2016 31.03.2019 TOLA not applicable 31.03.2022 TOLA not applicable 2016-2017 31.03.2020 30.06.2021 31.03.2023 TOLA not applicable 2017-2018 31.03.2021 30.06.2021 31.03.2024 TOLA not applicable f. The Revenue concedes that for the assessment year 2015-16, all notices issued on or after 1 April 2021 will have to be dropped as they will not fall for completion during the period prescribed under TOLA; ..................." 9. It is now crystal clear from the aforesaid decision of apex court in Rajeev Bansa....