https://www.taxtmi.com/caselaws?id=445872 Section 148 notices for AYs 2016-17 and 2017-18 were analysed under the amended limitation scheme in Section 149 of the Income-tax Act, 1961, which permits reassessment notices within three years from the end of the relevant assessment year unless the extended period applies for escapement of income of fifty lakh rupees or more. Because the alleged escaped income was below that threshold, the extended period was unavailable. The Delhi High Court also examined the effect of the Finance Act, 2021 regime and noted that post-01.04.2021 notices could not be treated as issued earlier through any legal fiction. On that basis, the CBDT Instruction dated 11.05.2022, to the extent it advanced a "travel back in time" theory, was treated as inconsistent with Section 149 and beyond Section 119. en-us Fri, 10 Nov 2023 00:00:00 +0530 Mon, 06 Jul 2026 14:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445872 Section 148 notices for AYs 2016-17 and 2017-18 were analysed under the amended limitation scheme in Section 149 of the Income-tax Act, 1961, which permits reassessment notices within three years from the end of the relevant assessment year unless the extended period applies for escapement of income of fifty lakh rupees or more. Because the alleged escaped income was below that threshold, the extended period was unavailable. The Delhi High Court also examined the effect of the Finance Act, 2021 regime and noted that post-01.04.2021 notices could not be treated as issued earlier through any legal fiction. On that basis, the CBDT Instruction dated 11.05.2022, to the extent it advanced a "travel back in time" theory, was treated as inconsistent with Section 149 and beyond Section 119. Case-Laws Income Tax Fri, 10 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445872