https://www.taxtmi.com/caselaws?id=759329 Delhi HC quashed reassessment notices under Section 148, ruling that proceedings initiated after Finance Act 2021 following Supreme Court's Abhisar Buildwell decision were time-barred under Section 149. The court held that while Abhisar Buildwell permitted reassessment after annulment of search assessments, such action must comply with statutory time limits. The First Proviso to Section 149(1) mandates reassessments for assessment years prior to April 1, 2021 must conform to pre-Finance Act 2021 time frames. Revenue's failure to initiate timely reassessment despite clear legal position rendered the notices invalid. en-us Thu, 26 Sep 2024 00:00:00 +0530 Mon, 20 Jan 2025 17:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759329 Delhi HC quashed reassessment notices under Section 148, ruling that proceedings initiated after Finance Act 2021 following Supreme Court's Abhisar Buildwell decision were time-barred under Section 149. The court held that while Abhisar Buildwell permitted reassessment after annulment of search assessments, such action must comply with statutory time limits. The First Proviso to Section 149(1) mandates reassessments for assessment years prior to April 1, 2021 must conform to pre-Finance Act 2021 time frames. Revenue's failure to initiate timely reassessment despite clear legal position rendered the notices invalid. Case-Laws Income Tax Thu, 26 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759329