https://www.taxtmi.com/caselaws?id=774379 Reopening of assessment under section 147 was contested on limitation and the transitional operation of TOLA. The court found that the revenue did not issue the preliminary compliance notice within the 30day window following the apex court decision, so the deemednotice mechanism could not validate the delayed notice; consequently the notice dated 31.03.2021 was timebarred under the controlling Supreme Court precedents and reassessment proceedings were set aside. The operative effect is that reopening founded on that notice is invalid and the assessment order stands in favour of the taxpayer. en-us Mon, 16 Jun 2025 00:00:00 +0530 Tue, 03 Feb 2026 14:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774379 Reopening of assessment under section 147 was contested on limitation and the transitional operation of TOLA. The court found that the revenue did not issue the preliminary compliance notice within the 30day window following the apex court decision, so the deemednotice mechanism could not validate the delayed notice; consequently the notice dated 31.03.2021 was timebarred under the controlling Supreme Court precedents and reassessment proceedings were set aside. The operative effect is that reopening founded on that notice is invalid and the assessment order stands in favour of the taxpayer. Case-Laws Income Tax Mon, 16 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774379