https://www.taxtmi.com/caselaws?id=771970 Reopening of assessment under Section 147 turned on the date of issuance of the Section 148 notice for limitation under Section 149(1). The notice was digitally signed and uploaded on 31.03.2021 but emailed and speed posted on 01.04.2021; the petitioner did not assert receipt on 31.03.2021. The court emphasised that a Section 148 notice is jurisdictional and that an invalid notice vitiates proceedings commenced thereunder; compliance with higher court directions is required when dates affect limitation. Applying those principles, the petitioner's challenge to the reassessment notice was rejected and the petition dismissed. en-us Wed, 28 May 2025 00:00:00 +0530 Mon, 09 Feb 2026 10:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771970 Reopening of assessment under Section 147 turned on the date of issuance of the Section 148 notice for limitation under Section 149(1). The notice was digitally signed and uploaded on 31.03.2021 but emailed and speed posted on 01.04.2021; the petitioner did not assert receipt on 31.03.2021. The court emphasised that a Section 148 notice is jurisdictional and that an invalid notice vitiates proceedings commenced thereunder; compliance with higher court directions is required when dates affect limitation. Applying those principles, the petitioner's challenge to the reassessment notice was rejected and the petition dismissed. Case-Laws Income Tax Wed, 28 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771970