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ITAT Delhi: Section 149 Limitation Invalidates Reassessment from Late Section 148 Notice

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Summary

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  • The ITAT Delhi has quashed the reassessment of Tillsoil Farms Pvt. Ltd. for AY 2013-14, ruling that the Section 148 notice issued on July 27, 2022, was time-barred under Section 149 of the Income-tax Act, 1961.
  • The Tribunal highlighted that the six-year limitation expired on June 30, 2021, making the subsequent notice invalid.
  • The company had initially reported an income of Rs. 49,31,568 but faced a significant addition of Rs. 1,09,58,000 due to discrepancies in asset declarations.
  • This ruling underscores the importance of adhering to statutory timelines in reassessment procedures and may influence future cases

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