Ranju Goel Vs Income Tax Officer, Ward-1, Karnal, Haryana

Parties Involved

Facts Summary

This appeal pertains to the assessment year 2013-14 and arises against the order of the Commissioner of Income Tax (Appeals)/NFAC, Delhi. The case involves the reopening of assessment under section 147 of the Income Tax Act, 1961, initiated by the Assessing Officer through a section 148 notice dated 30.04.2021. The assessee did not appear during the hearing, and the matter was proceeded ex-parte. The primary issue is the validity of the reopening itself, considering the limitation aspect under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). The department has conceded that TOLA does not apply to the assessment year 2013-14, as per the Supreme Court judgment in Union of India Vs. Rajiv Bansal (2024) 469 ITR 46 (SC). Additionally, a coordinate bench of the tribunal has quashed a similar reopening in ITA No. 2307/Del/2025 (Sh. Deepak Agarwal vs. DCIT).…

Legal Issues

• 1. Validity of the reopening of assessment under section 148 of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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