Grandfathering proviso to Section 149(1)(b) preserves...

Grandfathering proviso to Section 149(1)(b) preserves pre-amendment limitation computation for searches after 31.03.2021, so the amended ten-year reopening limit does not retrospectively extend time to reopen years already barred under the old regime; applying that principle the Tribunal found AY 2012-13 time barred. Section 148B is pari materia with prior law and requires prior approval founded on independent application of mind with year-wise appraisal of seized material; mechanical or omnibus approvals without examination of seized material vitiate the approval and render resultant assessments void, leading to quashing of assessments for the affected years.

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