https://www.taxtmi.com/caselaws?id=769009 The dominant issue was whether reassessment for AY 2015-16 was barred by limitation where a notice was issued under the pre-01.04.2021 s.148 regime and later treated under the post-01.04.2021 framework. Applying SC rulings, the HC held that the interregnum between the deemed notice dated 31.03.2021 and supply of material pursuant to SC directions must be excluded for computing limitation, and the notice cannot be "pigeonholed" under s.149(1)(a) so as to render proceedings still-born. Given the ingredients for invoking the extended period under the proviso to s.147 (old regime), the case fell within s.149(1)(b) (new regime), and the s.148A(d) order and s.148 notice dated 30.07.2022 were within time; the challenge was rejected. en-us Thu, 03 Apr 2025 00:00:00 +0530 Tue, 30 Dec 2025 16:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769009 The dominant issue was whether reassessment for AY 2015-16 was barred by limitation where a notice was issued under the pre-01.04.2021 s.148 regime and later treated under the post-01.04.2021 framework. Applying SC rulings, the HC held that the interregnum between the deemed notice dated 31.03.2021 and supply of material pursuant to SC directions must be excluded for computing limitation, and the notice cannot be "pigeonholed" under s.149(1)(a) so as to render proceedings still-born. Given the ingredients for invoking the extended period under the proviso to s.147 (old regime), the case fell within s.149(1)(b) (new regime), and the s.148A(d) order and s.148 notice dated 30.07.2022 were within time; the challenge was rejected. Case-Laws Income Tax Thu, 03 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769009