Deemed notices issued between 1 April 2021 and 30 June 2021...

Deemed notices issued between 1 April 2021 and 30 June 2021 stopped the limitation clock, and only the surviving balance period could be used for the section 148 notice after the section 148A(d) order. Applying that rule, no effective period remained for AY 2015-16, while only a short residual period survived for AYs 2016-17 and 2017-18, so the July 2022 notices were time-barred and jurisdictionally invalid. For AYs 2016-17 and 2017-18, approval from the Principal Commissioner was also insufficient because the statute required sanction from the competent authority under section 151(ii). The reassessment and the appellate remand were quashed.

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