https://www.taxtmi.com/caselaws?id=783572 Reassessment notices under s.148 for AYs 2002-03 and 2005-06 were issued beyond two years from the end of the relevant assessment years; the HC held they were time-barred, answering the limitation issue against the Revenue and invalidating the reassessment proceedings for those years. For AYs 2006-07 and 2007-08, the Assessing Authority had not passed any order under s.163 nor issued notice under s.163(2) before treating the assessee as a representative assessee/agent of a non-resident; the HC held this statutory precondition is mandatory, rejected reliance on the assessee's conduct, and upheld the Tribunal's view quashing the assessments dated 26.10.2010. en-us Mon, 01 Dec 2025 00:00:00 +0530 Thu, 18 Dec 2025 08:01:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783572 Reassessment notices under s.148 for AYs 2002-03 and 2005-06 were issued beyond two years from the end of the relevant assessment years; the HC held they were time-barred, answering the limitation issue against the Revenue and invalidating the reassessment proceedings for those years. For AYs 2006-07 and 2007-08, the Assessing Authority had not passed any order under s.163 nor issued notice under s.163(2) before treating the assessee as a representative assessee/agent of a non-resident; the HC held this statutory precondition is mandatory, rejected reliance on the assessee's conduct, and upheld the Tribunal's view quashing the assessments dated 26.10.2010. Case-Laws Income Tax Mon, 01 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783572