https://www.taxtmi.com/caselaws?id=769576 Reopening of assessment for the relevant year turns on whether the initial notice initiating proceedings falls within the three year limitation. The assessing officer issued a notice on 28.03.2024 which constitutes the initiating notice for limitation purposes; a later notice dated 22.04.2024 followed the taxpayer's reply and is not the relevant starting point. Legal consequence: the reassessment proceedings are within time and the AO has jurisdiction, and the writ challenging initiation was held premature while preserving the taxpayer's liberty to participate in the proceedings. en-us Wed, 05 Feb 2025 00:00:00 +0530 Sat, 21 Mar 2026 13:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769576 Reopening of assessment for the relevant year turns on whether the initial notice initiating proceedings falls within the three year limitation. The assessing officer issued a notice on 28.03.2024 which constitutes the initiating notice for limitation purposes; a later notice dated 22.04.2024 followed the taxpayer's reply and is not the relevant starting point. Legal consequence: the reassessment proceedings are within time and the AO has jurisdiction, and the writ challenging initiation was held premature while preserving the taxpayer's liberty to participate in the proceedings. Case-Laws Income Tax Wed, 05 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769576