https://www.taxtmi.com/caselaws?id=784613 The dominant issue was whether a reassessment notice issued under the post-01.04.2021 regime was barred by limitation under ss. 149 and 151, given that an earlier notice had been issued under the pre-amendment regime. Applying SC rulings in Ashish Agarwal and the LB decision in Rajeev Bansal, the HC held that a notice issued between 01.04.2021 and 30.06.2021 under the old regime is deemed a s. 148A(b) notice, and limitation must be computed by reading s. 149 with TOLA extensions and the first proviso to s. 149. Since alleged escapement exceeded ?50 lakh and the old-regime notice dated 30.06.2021 was within extended time, the subsequent s. 148 notice dated 29.07.2022 was within time and validly approved under s. 151; writ petition dismissed. en-us Fri, 28 Nov 2025 00:00:00 +0530 Thu, 08 Jan 2026 08:22:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784613 The dominant issue was whether a reassessment notice issued under the post-01.04.2021 regime was barred by limitation under ss. 149 and 151, given that an earlier notice had been issued under the pre-amendment regime. Applying SC rulings in Ashish Agarwal and the LB decision in Rajeev Bansal, the HC held that a notice issued between 01.04.2021 and 30.06.2021 under the old regime is deemed a s. 148A(b) notice, and limitation must be computed by reading s. 149 with TOLA extensions and the first proviso to s. 149. Since alleged escapement exceeded ?50 lakh and the old-regime notice dated 30.06.2021 was within extended time, the subsequent s. 148 notice dated 29.07.2022 was within time and validly approved under s. 151; writ petition dismissed. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784613