https://www.taxtmi.com/caselaws?id=782645 The ITAT Delhi-AT held the reassessment proceedings invalid and time-barred. Relying on the SC's interpretation of the "surviving time limit" under the amended reassessment regime read with TOLA, it held that the limitation clock begins when the Revenue receives the assessee's response to notice under section 148A(b). Thereafter, the AO must, within the surviving period, consider the reply under section 148A(c), decide under section 148A(d), and issue notice under section 148. As this timeline was breached, the reassessment was quashed and the assessee's additional grounds were allowed. en-us Fri, 21 Nov 2025 00:00:00 +0530 Mon, 06 Apr 2026 14:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782645 The ITAT Delhi-AT held the reassessment proceedings invalid and time-barred. Relying on the SC's interpretation of the "surviving time limit" under the amended reassessment regime read with TOLA, it held that the limitation clock begins when the Revenue receives the assessee's response to notice under section 148A(b). Thereafter, the AO must, within the surviving period, consider the reply under section 148A(c), decide under section 148A(d), and issue notice under section 148. As this timeline was breached, the reassessment was quashed and the assessee's additional grounds were allowed. Case-Laws Income Tax Fri, 21 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782645