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The first proviso to section 149(1)(b) preserves the...
Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier assessment years.
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The first proviso to section 149(1)(b) preserves the reassessment limitation available under the pre-amendment regime for assessment years commencing on or before 1 April 2021. The fifth and sixth provisos regulate computation under the amended three-year or ten-year framework but cannot extend that preserved limitation. Consequently, a reassessment notice for assessment year 2015-16 issued after expiry of six years from the end of the relevant assessment year was time-barred, and the consequential reassessment order was invalidated.
The first proviso to section 149(1)(b) preserves the reassessment limitation available under the pre-amendment regime for assessment years commencing on or before 1 April 2021. The fifth and sixth provisos regulate computation under the amended three-year or ten-year framework but cannot extend that preserved limitation. Consequently, a reassessment notice for assessment year 2015-16 issued after expiry of six years from the end of the relevant assessment year was time-barred, and the consequential reassessment order was invalidated.
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