The Court noted that the notice dated 27.07.2022 was issued beyond the permissible limitation period
The Delhi High Court, granting relief to MakeMyTrip, quashed a reassessment notice issued for Assessment Year(AY) 2015–16, holding it time-barred as the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA) did not apply to that year.
Make My Trip India Private Limited, petitioner-assessee, challenged a notice dated 27.07.2022 issued under Section 148 of the Income Tax Act for AY 2015–16, claiming it was time-barred. The original return was filed on 28.11.2015. Later, on 25.10.2017, the petitioner entered into an Advance Pricing Agreement (APA), which led to a modified return. This return was picked for scrutiny, and an assessment order under Section 143(3) was passed on 29.12.2018, assessing the income at ₹1,90,02,11,840.
The petitioner appealed the order, and on 24.06.2019, Commissioner of Income Tax(Appeals)[CIT(A)] allowed the appeal, setting…
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