No Tax Reassessment After 3 Years, regardless of Old or New Regime: Delhi High Court

The Delhi High Court ruled that the three-year time limit for income tax reassessment applies uniformly, regardless of whether the original assessment was conducted under the old or new tax regime. The court rejected the tax department's argument that shifting between tax regimes creates a fresh cause of action for reopening cases. This judgment protects taxpayers from facing reassessment proceedings for older years simply because they opted for the new tax regime in subsequent years. The court emphasized that the limitation period under Section 149 of the Income Tax Act is sacrosanct and cannot be extended through such technical interpretations. This precedent will prevent harassment of taxpayers who have switched regimes and provides much-needed certainty regarding the finality of assessments after the statutory time limit has expired.