Invalid Reassessment: Delhi ITAT Strikes Down Notice Issued Under Erstwhile Regime Post Implementation of New Law

The transition between old and new legal frameworks frequently gives rise to procedural disputes, particularly concerning the exact timing of administrative actions. In a recent judicial pronouncement, the Delhi Bench of the Income Tax Appellate Tribunal (ITAT) addressed one such critical overlap in the case of Anita Vs ITO (ITAT Delhi). The tribunal decisively nullified reassessment proceedings initiated against the assessee, establishing that notices dispatched under the former legal regime hold no legal sanctity if they are issued after the amended statutory provisions have officially come into force.

Background of the Dispute

The controversy pertained to the Assessment Year 2018-19. The foundational issue challenged by the assessee was the fundamental validity of the reopening of the assessment. The tax authorities had initiated proceedings invoking Section 147 read with Section 144 of the Income-tax Act, 1961.