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    <title>Reopening Notices Under Section 148 and 148A Subject to Limitation Period; Late Notices Quashed</title>
    <link>https://www.taxtmi.com/highlights?id=91136</link>
    <description>The HC held that reopening notices issued under section 148 between 01.04.2021 and 30.06.2021, treated as deemed notices under section 148A(b), followed by show-cause notices and orders under section 148A(d), and subsequent reassessment notices issued post-July 2022, were subject to the limitation regime under the amended provisions. Applying the Supreme Court&#039;s ruling in Rajeev Bansal, the court found that the impugned reassessment notices were issued beyond the prescribed limitation period. Consequently, all such notices were declared time-barred and quashed. The assessee&#039;s appeal was allowed, thereby invalidating the reopening of assessments under section 147 due to non-compliance with the statutory limitation framework as amended and extended during the COVID-19 period.</description>
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    <pubDate>Fri, 01 Aug 2025 08:15:08 +0530</pubDate>
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      <title>Reopening Notices Under Section 148 and 148A Subject to Limitation Period; Late Notices Quashed</title>
      <link>https://www.taxtmi.com/highlights?id=91136</link>
      <description>The HC held that reopening notices issued under section 148 between 01.04.2021 and 30.06.2021, treated as deemed notices under section 148A(b), followed by show-cause notices and orders under section 148A(d), and subsequent reassessment notices issued post-July 2022, were subject to the limitation regime under the amended provisions. Applying the Supreme Court&#039;s ruling in Rajeev Bansal, the court found that the impugned reassessment notices were issued beyond the prescribed limitation period. Consequently, all such notices were declared time-barred and quashed. The assessee&#039;s appeal was allowed, thereby invalidating the reopening of assessments under section 147 due to non-compliance with the statutory limitation framework as amended and extended during the COVID-19 period.</description>
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      <pubDate>Fri, 01 Aug 2025 08:15:08 +0530</pubDate>
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