https://www.taxtmi.com/caselaws?id=787419 For assessment years beginning on or before 1 April 2021, notices issued under the post 2021 reassessment regime must be tested against the limitation rules preserved by the first proviso to section 149(1)(b); applying the pre 2021 computation rules, the reopening for AY 2012 13 was time barred and invalid. Separately, prior approvals required under section 148B must show independent application of mind to the seized material for each assessment year; consolidated or omnibus approvals without examination of seized material are mechanical, invalidate the approvals, and vitiate consequent assessments. en-us Wed, 04 Feb 2026 00:00:00 +0530 Thu, 05 Mar 2026 08:41:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787419 For assessment years beginning on or before 1 April 2021, notices issued under the post 2021 reassessment regime must be tested against the limitation rules preserved by the first proviso to section 149(1)(b); applying the pre 2021 computation rules, the reopening for AY 2012 13 was time barred and invalid. Separately, prior approvals required under section 148B must show independent application of mind to the seized material for each assessment year; consolidated or omnibus approvals without examination of seized material are mechanical, invalidate the approvals, and vitiate consequent assessments. Case-Laws Income Tax Wed, 04 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787419