https://www.taxtmi.com/caselaws?id=770560 HC set aside a reopening notice u/s 148 issued for AY 2015-16 as time-barred under limitation provisions. The court applied the decision in Dinesh Jindal case, holding that reassessment actions initiated after 01 April 2021 must satisfy foundational tests under Section 149(1) First Proviso. Since the notice was issued on 30 March 2023, the six-year and ten-year limitation periods for computing validity under Section 153C had expired. The court calculated the block of ten assessment years from the end of AY 2025-26, being the relevant assessment year for the financial year when the notice was issued. The petition was allowed and the notice was quashed for being beyond the statutory limitation period. en-us Thu, 01 May 2025 00:00:00 +0530 Tue, 13 May 2025 09:17:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770560 HC set aside a reopening notice u/s 148 issued for AY 2015-16 as time-barred under limitation provisions. The court applied the decision in Dinesh Jindal case, holding that reassessment actions initiated after 01 April 2021 must satisfy foundational tests under Section 149(1) First Proviso. Since the notice was issued on 30 March 2023, the six-year and ten-year limitation periods for computing validity under Section 153C had expired. The court calculated the block of ten assessment years from the end of AY 2025-26, being the relevant assessment year for the financial year when the notice was issued. The petition was allowed and the notice was quashed for being beyond the statutory limitation period. Case-Laws Income Tax Thu, 01 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770560