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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Saktijit Dey, Vice-President, Makarand Vasant Mahadeokar, Accountant Member
Deepak Mahadeo Bhoir – Appellant
Versus
Income Tax Officer – Respondent
| Table of Content |
|---|
| 1. factual background of appeal and procedural history. (Para 1 , 2 , 3 , 8) |
| 2. assessee argues reassessment notice time-barred. (Para 4 , 5) |
| 3. revenue contends actions within limitation period. (Para 6) |
| 4. appeal allowed, assessment order set aside. (Para 7 , 18) |
| 5. analysis of precedents on limitation exclusions. (Para 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16) |
| 6. reassessment quashed as time-barred per binding precedents. (Para 17) |
ORDER
Per Saktijit Dey, Vice President:
This is an appeal by the assessee challenging the order dated 26.06.2024 passed by National Faceless Appeal Centre (NFAC), Delhi for the Assessment Year (A.Y.) 2013-14.
2. Before we proceed to decide the substantive issue arising for consideration, it is necessary to provide a brief factual background. This appeal was earlier disposed of by the Coordinate Bench vide order dated 12.12.2024. Subsequently, assessee filed a miscellaneous application seeking rectification/recall of the appellate order on the ground that while deciding the appeal, the Bench had failed to decide Ground No. 2.a and 2.b. While deciding the miscellaneous application, the Bench having found merit in the submissions of assessee, recalle
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