https://www.taxtmi.com/caselaws?id=783885 Reopening under ss.147/148 after 01.04.2021 was tested against the substituted reassessment regime read with TOLA; since the surviving limitation for issuing notice under s.148 (as extended) expired on 14.06.2022, a notice issued on 29.07.2022 was held time-barred and set aside. Independently, the notice was invalid for want of mandatory sanction under s.151, as the SC dispensation in Ashish Agarwal did not waive approval for s.148A(d) and s.148; the s.148 notice and consequential reassessment order were quashed and the appeal was allowed. The s.54F claim was remanded to the AO because the appellate authority failed to consider filed evidences. en-us Fri, 28 Nov 2025 00:00:00 +0530 Wed, 24 Dec 2025 07:51:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783885 Reopening under ss.147/148 after 01.04.2021 was tested against the substituted reassessment regime read with TOLA; since the surviving limitation for issuing notice under s.148 (as extended) expired on 14.06.2022, a notice issued on 29.07.2022 was held time-barred and set aside. Independently, the notice was invalid for want of mandatory sanction under s.151, as the SC dispensation in Ashish Agarwal did not waive approval for s.148A(d) and s.148; the s.148 notice and consequential reassessment order were quashed and the appeal was allowed. The s.54F claim was remanded to the AO because the appellate authority failed to consider filed evidences. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783885