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    <title>2025 (7) TMI 449 - GUJARAT HIGH COURT</title>
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    <description>Reassessment notice under Section 148 issued pursuant to the TOLA framework was held time-barred because the Revenue had to complete the remaining steps and issue the notice within the surviving limitation period after giving the assessee the statutory response opportunity. On the facts, the Section 148 notice was issued after that permissible period had expired, so it was without jurisdiction and invalid. The notice was therefore quashed as unsustainable in law.</description>
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      <title>2025 (7) TMI 449 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=774381</link>
      <description>Reassessment notice under Section 148 issued pursuant to the TOLA framework was held time-barred because the Revenue had to complete the remaining steps and issue the notice within the surviving limitation period after giving the assessee the statutory response opportunity. On the facts, the Section 148 notice was issued after that permissible period had expired, so it was without jurisdiction and invalid. The notice was therefore quashed as unsustainable in law.</description>
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