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    <title>2026 (3) TMI 816 - MADRAS HIGH COURT</title>
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    <description>Whether assessments already completed under the pre- or old-regime can be reopened by issuing fresh notices under the substituted reassessment procedure was the central issue; the court applied the principle of finality of assessment to hold that the Supreme Court directions validating procedural notices and the surviving limitation framework permit issuance and validation of notices that had not culminated in assessment within the surviving time limits, but do not require or permit reopening assessments already concluded on the merits. Outcome: impugned reassessment orders reopened those concluded assessments were set aside and relief granted to the assessee.</description>
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      <title>2026 (3) TMI 816 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=788061</link>
      <description>Whether assessments already completed under the pre- or old-regime can be reopened by issuing fresh notices under the substituted reassessment procedure was the central issue; the court applied the principle of finality of assessment to hold that the Supreme Court directions validating procedural notices and the surviving limitation framework permit issuance and validation of notices that had not culminated in assessment within the surviving time limits, but do not require or permit reopening assessments already concluded on the merits. Outcome: impugned reassessment orders reopened those concluded assessments were set aside and relief granted to the assessee.</description>
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