https://www.taxtmi.com/caselaws?id=448404 The Bombay HC quashed a reassessment notice dated 28th July 2022 for AY 2013-14 as barred by limitation. The court held that under unamended Section 149(1)(b), the six-year time limit to issue notices under Section 148 expired on 31st March 2020, extended to 31st March 2021 under TOLA. The amended provision's first proviso prevents issuing notices if they were already time-barred under the pre-amended Act. Since the impugned notice was issued beyond the extended limitation period, it was invalid. The court rejected the Revenue's arguments regarding TOLA's applicability and the relate-back theory, ruling in favor of the assessee. en-us Mon, 15 Jan 2024 00:00:00 +0530 Wed, 27 Mar 2024 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448404 The Bombay HC quashed a reassessment notice dated 28th July 2022 for AY 2013-14 as barred by limitation. The court held that under unamended Section 149(1)(b), the six-year time limit to issue notices under Section 148 expired on 31st March 2020, extended to 31st March 2021 under TOLA. The amended provision's first proviso prevents issuing notices if they were already time-barred under the pre-amended Act. Since the impugned notice was issued beyond the extended limitation period, it was invalid. The court rejected the Revenue's arguments regarding TOLA's applicability and the relate-back theory, ruling in favor of the assessee. Case-Laws Income Tax Mon, 15 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448404