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    <title>2025 (7) TMI 943 - ITAT MUMBAI</title>
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    <description>Reassessment notices under the new regime were invalid where they were issued beyond the surviving limitation period and where approval was taken from the wrong specified authority. For Assessment Year 2015-16, the notice issued after expiry of the six-year period was not saved by TOLA and the resulting reassessment was quashed. For Assessment Year 2016-17, the notice was issued after three years and required sanction under section 151(ii) from the higher specified authority; approval from the Principal Commissioner was insufficient, so the notice and reassessment were also quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=774875</link>
      <description>Reassessment notices under the new regime were invalid where they were issued beyond the surviving limitation period and where approval was taken from the wrong specified authority. For Assessment Year 2015-16, the notice issued after expiry of the six-year period was not saved by TOLA and the resulting reassessment was quashed. For Assessment Year 2016-17, the notice was issued after three years and required sanction under section 151(ii) from the higher specified authority; approval from the Principal Commissioner was insufficient, so the notice and reassessment were also quashed.</description>
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