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Judgment
This assessee’s appeal for assessment year 2014-15, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1071383564(1), dated 19.12.2024 involving proceedings under section 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It transpires during the course of hearing that the learned assessing authority had initiated the impugned reopening against the assessee thereby issuance of section 148 notice in issue dated 23.07.2022. This is being the clinching information, the revenue hardly dispute that the aforesaid notice is indeed a time-barred one going by UOI & Ors. Vs Rajeev Bansal [2024] 469 ITR 46 (SC) wherein the lordship made it clear that time limit for issuing such a notice would be up to 30th June 2021 only. The impugned reopening stands quashed for the very precise reason therefore.
All the remaining pleadings between the partis rendered academic.
The assessee’s appeal is allowed.