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Reassessment proceedings initiated beyond statutory time limit prescribed under pre-amended Section 149(1)(b) quashed. Notice u/s 148 issued after expiry of six-year period from end of relevant assessment year held impermissible. Statutory time limit not extendable through judicial interpretation or by invoking other provisions. Writ petition allowed, impugned order u/s 148A(d) and consequential notice u/s 148 quashed.
Reassessment proceedings initiated beyond statutory time limit prescribed under pre-amended Section 149(1)(b) quashed. Notice u/s 148 issued after expiry of six-year period from end of relevant assessment year held impermissible. Statutory time limit not extendable through judicial interpretation or by invoking other provisions. Writ petition allowed, impugned order u/s 148A(d) and consequential notice u/s 148 quashed.
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