https://www.taxtmi.com/caselaws?id=461781 Under the substituted reassessment regime, notices originally issued under the old procedure were to be tested against the amended limitation framework, including the exclusions recognised by the Supreme Court. On the facts, the section 148A(d) order and fresh section 148 notice were issued within the permitted time after the assessee's reply, so the challenge to reopening failed. On the Income Declaration Scheme issue, the assessee claimed that tax had been paid in substance, though across two PAN numbers; because the record had not fully verified that position, the addition was restored to the Assessing Officer for factual examination. en-us Wed, 04 Dec 2024 00:00:00 +0530 Mon, 28 Apr 2025 19:07:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461781 Under the substituted reassessment regime, notices originally issued under the old procedure were to be tested against the amended limitation framework, including the exclusions recognised by the Supreme Court. On the facts, the section 148A(d) order and fresh section 148 notice were issued within the permitted time after the assessee's reply, so the challenge to reopening failed. On the Income Declaration Scheme issue, the assessee claimed that tax had been paid in substance, though across two PAN numbers; because the record had not fully verified that position, the addition was restored to the Assessing Officer for factual examination. Case-Laws Income Tax Wed, 04 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461781