https://www.taxtmi.com/caselaws?id=785057 A 26-day delay in filing the appeal was condoned on a liberal, justice-oriented assessment, as the explanation was supported by affidavit and showed no deliberate inaction or mala fides. On reassessment, the electronic record showed that the notice under section 148 was actually communicated by email on 01.04.2021; mere generation or portal dispatch on 31.03.2021 did not amount to issuance. As the substituted reassessment regime applied from 01.04.2021, prior compliance with section 148A was mandatory. Because that procedure was not followed, the reassessment proceedings suffered from a jurisdictional defect and the reassessment orders could not be sustained. en-us Wed, 07 Jan 2026 00:00:00 +0530 Fri, 16 Jan 2026 08:03:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785057 A 26-day delay in filing the appeal was condoned on a liberal, justice-oriented assessment, as the explanation was supported by affidavit and showed no deliberate inaction or mala fides. On reassessment, the electronic record showed that the notice under section 148 was actually communicated by email on 01.04.2021; mere generation or portal dispatch on 31.03.2021 did not amount to issuance. As the substituted reassessment regime applied from 01.04.2021, prior compliance with section 148A was mandatory. Because that procedure was not followed, the reassessment proceedings suffered from a jurisdictional defect and the reassessment orders could not be sustained. Case-Laws Income Tax Wed, 07 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785057