https://www.taxtmi.com/highlights?id=85208 HC held reassessment proceedings initiated u/s 148 were invalid due to statutory limitation u/s 149. The original notice was set aside for lacking mandatory approvals from competent authority. Court rejected Revenue's argument that limitation period should be extended due to prior litigation, stating time spent in previous challenges cannot extend statutory limitation periods. The fact that Revenue failed to take proper legal steps within prescribed timeframe cannot be used to justify extension of limitation period. No court order prevented Revenue from issuing valid notice within limitation period. Petition allowed, reassessment order and notices quashed as time-barred. Litigation time exclusion claim denied as limitation u/s 149 remained absolute. en-us Mon, 27 Jan 2025 08:40:02 +0530 Mon, 27 Jan 2025 08:40:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=85208 HC held reassessment proceedings initiated u/s 148 were invalid due to statutory limitation u/s 149. The original notice was set aside for lacking mandatory approvals from competent authority. Court rejected Revenue's argument that limitation period should be extended due to prior litigation, stating time spent in previous challenges cannot extend statutory limitation periods. The fact that Revenue failed to take proper legal steps within prescribed timeframe cannot be used to justify extension of limitation period. No court order prevented Revenue from issuing valid notice within limitation period. Petition allowed, reassessment order and notices quashed as time-barred. Litigation time exclusion claim denied as limitation u/s 149 remained absolute. Highlights Income Tax Mon, 27 Jan 2025 08:40:02 +0530 https://www.taxtmi.com/highlights?id=85208