https://www.taxtmi.com/caselaws?id=765172 The HC held that reopening of assessment under section 148 is barred by limitation as prescribed under section 149. Notices issued under section 148 before 01.04.2021 but after that date are to be treated as notices under section 148A(b). The notice issued without mandatory approval was invalid, and the time spent by the assessee in challenging the notice cannot be excluded or extend the limitation period. The Revenue must initiate proceedings within the prescribed limitation period following proper legal steps. Absence of court orders restraining the Revenue does not justify extending limitation. The HC rejected the Revenue's contention that limitation was extended due to earlier proceedings and quashed the reassessment order and notices, ruling in favor of the assessee. en-us Wed, 15 Jan 2025 00:00:00 +0530 Mon, 04 Aug 2025 16:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765172 The HC held that reopening of assessment under section 148 is barred by limitation as prescribed under section 149. Notices issued under section 148 before 01.04.2021 but after that date are to be treated as notices under section 148A(b). The notice issued without mandatory approval was invalid, and the time spent by the assessee in challenging the notice cannot be excluded or extend the limitation period. The Revenue must initiate proceedings within the prescribed limitation period following proper legal steps. Absence of court orders restraining the Revenue does not justify extending limitation. The HC rejected the Revenue's contention that limitation was extended due to earlier proceedings and quashed the reassessment order and notices, ruling in favor of the assessee. Case-Laws Income Tax Wed, 15 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765172