https://www.taxtmi.com/caselaws?id=465381 The dominant issue was whether a reassessment notice issued under the "new regime" provisions of ss. 147/148 could be sustained when issued after expiry of six years from the end of the relevant AY, and whether the ten-year limit in s. 149(1)(b) could be applied retrospectively. The HC held that a notice under s. 148 in the new regime cannot be issued once the six-year period has expired at the time of issuance, and this construction ensures the ten-year period operates only prospectively. Since six years for AY 2016-17 expired on 31.03.2023 and the notice was issued thereafter, it was barred by limitation; the writ petition was allowed and the notice was quashed. en-us Wed, 09 Oct 2024 00:00:00 +0530 Wed, 17 Dec 2025 16:34:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465381 The dominant issue was whether a reassessment notice issued under the "new regime" provisions of ss. 147/148 could be sustained when issued after expiry of six years from the end of the relevant AY, and whether the ten-year limit in s. 149(1)(b) could be applied retrospectively. The HC held that a notice under s. 148 in the new regime cannot be issued once the six-year period has expired at the time of issuance, and this construction ensures the ten-year period operates only prospectively. Since six years for AY 2016-17 expired on 31.03.2023 and the notice was issued thereafter, it was barred by limitation; the writ petition was allowed and the notice was quashed. Case-Laws Income Tax Wed, 09 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465381