https://www.taxtmi.com/caselaws?id=765280 The reassessment notice was found to be barred by limitation because it was issued after the ordinary six-year period and beyond the extended time available under TOLA as applied in light of the Supreme Court's interpretation of the substituted reassessment regime. The Tribunal noted that the relaxation under section 3(1) of TOLA extends the limitation only to the extent recognised by the Supreme Court, and notices issued after the surviving period remain time barred. As the notice dated 29/07/2022 was issued after the extended limitation had expired on 30/06/2021, it was treated as invalid and set aside, making consideration of the merits unnecessary. en-us Mon, 06 Jan 2025 00:00:00 +0530 Wed, 29 Jan 2025 09:00:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765280 The reassessment notice was found to be barred by limitation because it was issued after the ordinary six-year period and beyond the extended time available under TOLA as applied in light of the Supreme Court's interpretation of the substituted reassessment regime. The Tribunal noted that the relaxation under section 3(1) of TOLA extends the limitation only to the extent recognised by the Supreme Court, and notices issued after the surviving period remain time barred. As the notice dated 29/07/2022 was issued after the extended limitation had expired on 30/06/2021, it was treated as invalid and set aside, making consideration of the merits unnecessary. Case-Laws Income Tax Mon, 06 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765280