https://www.taxtmi.com/caselaws?id=756004 The ITAT Mumbai held that reassessment proceedings initiated under Section 147 were invalid as they exceeded the time limit prescribed under Section 149. The tribunal ruled that the Finance Bill 2021 amendment did not permit issuance of notices that were previously barred by limitation for assessment years beginning on or before April 1, 2021. The principle established was that actions prohibited under earlier provisions remain prohibited post-amendment. Consequently, the impugned notice and proceedings were quashed, with the decision favoring the assessee. en-us Mon, 22 Jul 2024 00:00:00 +0530 Mon, 16 Dec 2024 12:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756004 The ITAT Mumbai held that reassessment proceedings initiated under Section 147 were invalid as they exceeded the time limit prescribed under Section 149. The tribunal ruled that the Finance Bill 2021 amendment did not permit issuance of notices that were previously barred by limitation for assessment years beginning on or before April 1, 2021. The principle established was that actions prohibited under earlier provisions remain prohibited post-amendment. Consequently, the impugned notice and proceedings were quashed, with the decision favoring the assessee. Case-Laws Income Tax Mon, 22 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756004