https://www.taxtmi.com/caselaws?id=782152 The dominant issue was the validity of reassessment notices issued under the post-2021 regime in light of limitation under s. 149 read with TOLA, particularly whether the extended 10-year period could be invoked for AY 2021-22 and earlier despite expiry of the 6-year period under the pre-amendment regime. Applying the binding ratio in a prior SC decision, the Court held that issuance of notice under s. 148 is barred where the pre-amendment 6-year limitation had already expired on the date of notice, and the amended 10-year window under s. 149 operates prospectively. The revenue's SLPs were disposed of accordingly, with objections to be decided by the AO per SC law. en-us Fri, 21 Nov 2025 00:00:00 +0530 Mon, 22 Dec 2025 10:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782152 The dominant issue was the validity of reassessment notices issued under the post-2021 regime in light of limitation under s. 149 read with TOLA, particularly whether the extended 10-year period could be invoked for AY 2021-22 and earlier despite expiry of the 6-year period under the pre-amendment regime. Applying the binding ratio in a prior SC decision, the Court held that issuance of notice under s. 148 is barred where the pre-amendment 6-year limitation had already expired on the date of notice, and the amended 10-year window under s. 149 operates prospectively. The revenue's SLPs were disposed of accordingly, with objections to be decided by the AO per SC law. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782152