https://www.taxtmi.com/caselaws?id=467032 Section 148 reassessment notices for AY 2015-16 remain governed by the six-year limitation under the former Section 149 where that period had expired before issuance. The TOLA extension framework and amended ten-year limitation do not retrospectively validate notices for earlier years once the former limitation expired. For AY 2015-16, the six-year period ended on 31 March 2022; therefore, a notice issued on 22 July 2022 is time-barred. Reassessment founded on such a notice lacks jurisdiction and is liable to be quashed, rendering merits issues academic. en-us Wed, 24 Dec 2025 00:00:00 +0530 Mon, 02 Mar 2026 12:09:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467032 Section 148 reassessment notices for AY 2015-16 remain governed by the six-year limitation under the former Section 149 where that period had expired before issuance. The TOLA extension framework and amended ten-year limitation do not retrospectively validate notices for earlier years once the former limitation expired. For AY 2015-16, the six-year period ended on 31 March 2022; therefore, a notice issued on 22 July 2022 is time-barred. Reassessment founded on such a notice lacks jurisdiction and is liable to be quashed, rendering merits issues academic. Case-Laws Income Tax Wed, 24 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467032