Service-tax exemptions for railway and Government works restrict de novo reassessment, while unsupported limitation and consultation failures invalida...
Reassessment under the substituted Income-tax Act framework must comply with Sections 148, 148A, 149 and 151, with TOLA extending only qualifying statutory deadlines rather than preserving the repealed regime. Transitional notices issued between 1 April and 30 June 2021 and deemed Section 148A(b) notices leave only the time surviving to 30 June 2021, excluding deemed-stay and assessee-response periods; Section 148A(d) cannot enlarge Section 149 limitation. The first proviso to Section 149 prevents retrospective revival where the former limitation had expired, while valid approval remains jurisdictional. For Assessment Year 2015-16, post-1 April 2021 notices are time-barred and require determination before merits or other procedural objections.
Reassessment under the substituted Income-tax Act framework must comply with Sections 148, 148A, 149 and 151, with TOLA extending only qualifying statutory deadlines rather than preserving the repealed regime. Transitional notices issued between 1 April and 30 June 2021 and deemed Section 148A(b) notices leave only the time surviving to 30 June 2021, excluding deemed-stay and assessee-response periods; Section 148A(d) cannot enlarge Section 149 limitation. The first proviso to Section 149 prevents retrospective revival where the former limitation had expired, while valid approval remains jurisdictional. For Assessment Year 2015-16, post-1 April 2021 notices are time-barred and require determination before merits or other procedural objections.
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