https://www.taxtmi.com/caselaws?id=449553 Reassessment notices issued after 1 April 2021 under extensions granted by TOLA could not continue the repealed reassessment framework. The Finance Act, 2021 substituted the reassessment provisions and introduced Section 148A without preserving the former regime. TOLA could relax limitation only under the pre-amendment law and did not authorise revival or extension of provisions that had ceased to operate. CBDT notifications extending the former regime beyond 31 March 2021 therefore conflicted with the substituted statutory scheme. Limitation defences under amended Section 149 remained available, rendering the relevant notices and consequential reassessment proceedings time-barred and legally unsustainable. en-us Fri, 09 Feb 2024 00:00:00 +0530 Fri, 17 Jul 2026 17:45:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449553 Reassessment notices issued after 1 April 2021 under extensions granted by TOLA could not continue the repealed reassessment framework. The Finance Act, 2021 substituted the reassessment provisions and introduced Section 148A without preserving the former regime. TOLA could relax limitation only under the pre-amendment law and did not authorise revival or extension of provisions that had ceased to operate. CBDT notifications extending the former regime beyond 31 March 2021 therefore conflicted with the substituted statutory scheme. Limitation defences under amended Section 149 remained available, rendering the relevant notices and consequential reassessment proceedings time-barred and legally unsustainable. Case-Laws Income Tax Fri, 09 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449553