https://www.taxtmi.com/caselaws?id=466087 Validity of reopening of assessment is examined in light of limitation suspension under TOLA and the new reassessment regime. The assessment years three-year period expired during the TOLA suspension, so the authority specified for post-expiry approvals under the new regime ought to have been the higher sanctioning authority; instead approval was granted by a lower authority and a notice was issued after the three-year period. Applying the principle that notices falling in the interregnum are deemed dated earlier, the revenue lacked time to complete the new-regime procedure, rendering the subsequent notice void ab initio and quashed in favour of the assessee. en-us Fri, 31 Oct 2025 00:00:00 +0530 Thu, 22 Jan 2026 15:37:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466087 Validity of reopening of assessment is examined in light of limitation suspension under TOLA and the new reassessment regime. The assessment years three-year period expired during the TOLA suspension, so the authority specified for post-expiry approvals under the new regime ought to have been the higher sanctioning authority; instead approval was granted by a lower authority and a notice was issued after the three-year period. Applying the principle that notices falling in the interregnum are deemed dated earlier, the revenue lacked time to complete the new-regime procedure, rendering the subsequent notice void ab initio and quashed in favour of the assessee. Case-Laws Income Tax Fri, 31 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466087