https://www.taxtmi.com/caselaws?id=767068 The dominant issue was whether reassessment reopening under ss. 147/148 was time-barred, including the extent to which the extended period under the TOLA could save the notice. Applying s. 149 (pre-Finance Act 2021) and the SC's construction in Ashish Agarwal as clarified in Rajeev Bansal, the ITAT held that only the "surviving time" under the Act read with TOLA remained available for issuance of a reassessment notice under the new regime after completion of s. 148A(b) process. On the facts, the revenue's surviving window had expired before the notice dated 29.07.2022, rendering the notice beyond limitation; the reopening was quashed and relief granted to the assessee. en-us Thu, 06 Mar 2025 00:00:00 +0530 Mon, 05 Jan 2026 14:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767068 The dominant issue was whether reassessment reopening under ss. 147/148 was time-barred, including the extent to which the extended period under the TOLA could save the notice. Applying s. 149 (pre-Finance Act 2021) and the SC's construction in Ashish Agarwal as clarified in Rajeev Bansal, the ITAT held that only the "surviving time" under the Act read with TOLA remained available for issuance of a reassessment notice under the new regime after completion of s. 148A(b) process. On the facts, the revenue's surviving window had expired before the notice dated 29.07.2022, rendering the notice beyond limitation; the reopening was quashed and relief granted to the assessee. Case-Laws Income Tax Thu, 06 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767068