Case Law Analysis
|Income Tax Appellate Tribunal
Section 148 IT Act | Reassessment Notice Issued After 01.04.2021 for A.Y. 2015-16 Barred by Limitation Under Rajeev Bansal : ITAT Delhi
ITAT Delhi has ruled that reassessment notices issued under Section 148 after 1 April 2021 for assessment years prior to 2017-18 are time-barred if the original assessment was never completed under Section 143(3), reinforcing that the amended limitation period applies retroactively to protect taxpayers from stale reassessments. This decision impacts thousands of pending cases where notices were issued based on old procedural norms.