https://www.taxtmi.com/caselaws?id=785377 Under the reassessment regime, a notice under the new Section 148 cannot be issued where the limitation period preserved by the first proviso to Section 149(1)(b) has expired. The text notes that for assessment years 2021-22 and earlier, the new-regime notice is available only if the time limit for issuance continued to exist under the old regime; once six years from the end of the relevant assessment year had lapsed, issuance of notice is barred. The special leave petition was dismissed for delay, as no sufficient explanation was shown to condone a 320-day delay. en-us Mon, 19 Jan 2026 00:00:00 +0530 Thu, 22 Jan 2026 08:41:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785377 Under the reassessment regime, a notice under the new Section 148 cannot be issued where the limitation period preserved by the first proviso to Section 149(1)(b) has expired. The text notes that for assessment years 2021-22 and earlier, the new-regime notice is available only if the time limit for issuance continued to exist under the old regime; once six years from the end of the relevant assessment year had lapsed, issuance of notice is barred. The special leave petition was dismissed for delay, as no sufficient explanation was shown to condone a 320-day delay. Case-Laws Income Tax Mon, 19 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785377