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    <title>2025 (11) TMI 1669 - ITAT DELHI</title>
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    <description>Reassessment notice issued for Assessment Year 2015-16 after 1 April 2021 was treated as beyond the limitation period, because TOLA did not extend the time available for such action in the circumstances. The Tribunal applied the binding position in Rajeev Bansal and noted the Revenue&#039;s concession that notices for that assessment year issued on or after 1 April 2021 would not survive under TOLA. The reassessment proceedings were therefore held time barred, and the assessment made pursuant to them was unsustainable and invalid in favour of the assessee.</description>
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      <title>2025 (11) TMI 1669 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782201</link>
      <description>Reassessment notice issued for Assessment Year 2015-16 after 1 April 2021 was treated as beyond the limitation period, because TOLA did not extend the time available for such action in the circumstances. The Tribunal applied the binding position in Rajeev Bansal and noted the Revenue&#039;s concession that notices for that assessment year issued on or after 1 April 2021 would not survive under TOLA. The reassessment proceedings were therefore held time barred, and the assessment made pursuant to them was unsustainable and invalid in favour of the assessee.</description>
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