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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Yogesh Kumar U.S., Judicial Member, Manish Agarwal, Accountant Member
TRDP Happy World Pvt. Ltd. – Appellant
Versus
Deputy Commissioner of Income Tax – Respondent
| Table of Content |
|---|
| 1. nature of the appeal and the order challenged. (Para 1) |
| 2. submission of contentions regarding the limitation period for reassessment notice. (Para 2 , 3 , 4) |
| 3. analysis of section 149(1)(b) criteria for extending reassessment limitation beyond three years. (Para 5 , 6) |
| 4. application of law: reassessment is invalid if conditions under section 149(1)(b) are not satisfied. (Para 7) |
| 5. final outcome of the appeal. (Para 8) |
| TRDP Happy World Pvt.Ltd. 92, Chanderlok, Pitampura, New DelhiPAN: AAGCA5328L |
Vs | Deputy Commissioner of Income Tax, E-2, ARA Centre, Jhandewalan Extension, Delhi |
| Appellant | Respondent | |
| Assessee by Sh. Amit Goel, CA & Sh. Pranav Yadav, Adv | ||
| Revenue by Sh. Dayainder Singh Sidhu, CIT (DR) | ||
| Date of Hearing 24/03/2026 | ||
| Date of Pronouncement 19/05/2026 | ||
ORDER
PER YOGESH KUMAR, U.S. JM:
The present appeal is filed by the Assessee against the order of Ld. Commissioner of Income Tax (Appeals)-27, (‘Ld. CIT(A)/NFAC’ for short), New Delhi dated 29/08/2025 for the Assessment Year 2018-19.
2. The grounds of Appeal are as under:-
“1. On the facts and circumstances of the case and in law, the notice u/s 148 issued in this case is bad-in-law, illegal, without ju
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