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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Anubhav Sharma, Judicial Member, Manish Agarwal, Accountant Member
Kaushalya Gupta – Appellant
Versus
Income Tax Department – Respondent
| Table of Content |
|---|
| 1. assessee challenges reassessment on limitation grounds for ay 2013-14. (Para 1 , 2 , 3) |
| 2. s.148 notice time-barred beyond surviving 22 tola days post-reply. (Para 4 , 7) |
| 3. high court precedents affirm truncation of s.148a timelines. (Para 5 , 6) |
| 4. reassessment facts and ay 2015-16 reopening challenged. (Para 10 , 11 , 12) |
| 5. revenue concedes dropping ay 2015-16 notices post-april 2021. (Para 13 , 14 , 15) |
| 6. both appeals allowed; reassessments quashed as invalid. (Para 16 , 17 , 18 , 19 , 20) |
ORDER
PER MANISH AGARWAL, AM:
These two appeals are filed by the assessee against the order of Ld. Commissioner of Income Tax (Appeals) National Faceless Appeal Centre (NFAC), Delhi [“CIT(A)”, in short] in Appeal No. NFAC/2012-13/10290290 and NFAC/2014-15/10290307, both dated 12.08.2025 u/s 250 of the Income Tax Act, 1961 (“the Act”) arising out of the orders passed u/s 147 of the Act dated 18.05.2023 and 24.05.2023 for Assessment Years 2013-14 and 2015-16 respectively.
ITA No. 6447/Del/2025 [AY 2013-14]
2. First we take appeal filed by the assessee for AY 2013-14 in ITA No. 6447/Del/2025 wherein Ground of appeal No. 1, the assessee has raised legal issue of limitations on account
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