https://www.taxtmi.com/caselaws?id=434718 The HC held the reassessment notices under section 148 and the orders under section 148A(d) to be time-barred for the relevant assessment years (AY 2013-14 and AY 2014-15) and quashed them. The court ruled the TOLA Act and departmental notifications could not extend the six-year limitation under the unamended section 149(1)(b) after substitution by the Finance Act, 2021, and that the Finance Act's first proviso preserves the pre-amendment six-year bar. Reliance on delegated notifications was rejected; other legal and factual defenses were left open. en-us Tue, 07 Feb 2023 00:00:00 +0530 Wed, 27 Aug 2025 15:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434718 The HC held the reassessment notices under section 148 and the orders under section 148A(d) to be time-barred for the relevant assessment years (AY 2013-14 and AY 2014-15) and quashed them. The court ruled the TOLA Act and departmental notifications could not extend the six-year limitation under the unamended section 149(1)(b) after substitution by the Finance Act, 2021, and that the Finance Act's first proviso preserves the pre-amendment six-year bar. Reliance on delegated notifications was rejected; other legal and factual defenses were left open. Case-Laws Income Tax Tue, 07 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434718