https://www.taxtmi.com/caselaws?id=776267 The HC held that the reopening notice issued beyond four years for AY 2015-16 falls under the old regime as the extended time limit applies between 20.03.2020 and 31.03.2021. Under the old regime, the Joint Commissioner must be satisfied with the Assessing Officer's reasons before issuing a notice under Section 148. The notice in question was issued with the satisfaction of the PCIT, Panaji, who is not the competent authority under Section 151(2). Consequently, the notice dated 31.03.2021 was invalid. The HC quashed and set aside the reopening notice, allowing the assessee's appeal. en-us Mon, 21 Jul 2025 00:00:00 +0530 Thu, 07 Aug 2025 10:12:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776267 The HC held that the reopening notice issued beyond four years for AY 2015-16 falls under the old regime as the extended time limit applies between 20.03.2020 and 31.03.2021. Under the old regime, the Joint Commissioner must be satisfied with the Assessing Officer's reasons before issuing a notice under Section 148. The notice in question was issued with the satisfaction of the PCIT, Panaji, who is not the competent authority under Section 151(2). Consequently, the notice dated 31.03.2021 was invalid. The HC quashed and set aside the reopening notice, allowing the assessee's appeal. Case-Laws Income Tax Mon, 21 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776267