https://www.taxtmi.com/caselaws?id=467305 Reassessment notice for AY 2015-16 was held invalid because the later notice under section 148 was issued after the applicable limitation period had expired. The first notice issued on 06.04.2021 was treated as a notice under section 148A(b) in line with Ashish Agarwal, but the subsequent order under section 148A(d) and fresh notice dated 29.07.2022 could not revive a time-barred reassessment. Applying Rajiv Bansal, the Tribunal held that TOLA relaxation was unavailable for this assessment year, so the reassessment proceedings could not be sustained and the assessee succeeded on the jurisdictional issue. en-us Wed, 19 Nov 2025 00:00:00 +0530 Fri, 13 Mar 2026 18:58:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467305 Reassessment notice for AY 2015-16 was held invalid because the later notice under section 148 was issued after the applicable limitation period had expired. The first notice issued on 06.04.2021 was treated as a notice under section 148A(b) in line with Ashish Agarwal, but the subsequent order under section 148A(d) and fresh notice dated 29.07.2022 could not revive a time-barred reassessment. Applying Rajiv Bansal, the Tribunal held that TOLA relaxation was unavailable for this assessment year, so the reassessment proceedings could not be sustained and the assessee succeeded on the jurisdictional issue. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467305