https://www.taxtmi.com/highlights?id=97828 The first proviso to the limitation provision in section 149(1) restricts retrospective application of the post-2021 ten-year reopening window; for assessment years beginning on or before 1 April 2021 a reopening notice under section 148 is valid only if the pre-2021 (six-year) limitation continued to apply. Applying the Supreme Court ratio in Rajeev Bansal, the court found the six-year period for AY 2013-14 had expired (extended relief aside) before the 2021 amendment took effect, so notices issued in 2024 were time-barred and were quashed. en-us Wed, 18 Mar 2026 08:21:00 +0530 Wed, 18 Mar 2026 08:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97828 The first proviso to the limitation provision in section 149(1) restricts retrospective application of the post-2021 ten-year reopening window; for assessment years beginning on or before 1 April 2021 a reopening notice under section 148 is valid only if the pre-2021 (six-year) limitation continued to apply. Applying the Supreme Court ratio in Rajeev Bansal, the court found the six-year period for AY 2013-14 had expired (extended relief aside) before the 2021 amendment took effect, so notices issued in 2024 were time-barred and were quashed. Highlights Income Tax Wed, 18 Mar 2026 08:21:00 +0530 https://www.taxtmi.com/highlights?id=97828