Amish Aggarwal vs. ITO, Ward 8(1)

Parties Involved

Facts Summary

The appeal by the assessee, Amish Aggarwal, is against the order of the National Faceless Appeal Centre (NFAC), Delhi dated 10.3.2026. The assessment was framed under section 147 of the Income Tax Act, 1961, relevant to the assessment year 2015-16. The primary issue is the validity of the reopening of the assessment set into motion by the Assessing Officer via a section 148 notice issued on 26.07.2022. The department conceded the limitation aspect in Union of India Vs. Rajiv Bansal (2024) 469 ITR 46 (SC). The issue is no longer res integra due to a recent order by a coordinate bench of the tribunal in ITA No. 2307/Del/2025 (Sh. Deepak Agarwal vs. DCIT). The reassessment based on the notice issued under section 148 of the Act dated 30.07.2022 is time-barred and bad in law.…

Legal Issues

• 1. Validity of the reopening of the assessment set into motion by the Assessing Officer via a section 148 notice issued on 26.07.2022.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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