https://www.taxtmi.com/caselaws?id=467520 A notice under Section 148 for AY 2017-18 was held time-barred because the first proviso to amended Section 149 barred reopening where the notice could not have been issued within the pre-amendment limitation period; the extended-procedure provisos did not revive an already barred notice. The Court also held that reassessment could not be initiated on matters already subject to pending rectification proceedings under Section 154, where the grounds substantially overlapped, including provident fund disallowance and depreciation issues. On both limitation and overlapping proceedings, the reopening was unsustainable and was set aside. en-us Mon, 17 Nov 2025 00:00:00 +0530 Mon, 23 Mar 2026 10:16:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467520 A notice under Section 148 for AY 2017-18 was held time-barred because the first proviso to amended Section 149 barred reopening where the notice could not have been issued within the pre-amendment limitation period; the extended-procedure provisos did not revive an already barred notice. The Court also held that reassessment could not be initiated on matters already subject to pending rectification proceedings under Section 154, where the grounds substantially overlapped, including provident fund disallowance and depreciation issues. On both limitation and overlapping proceedings, the reopening was unsustainable and was set aside. Case-Laws Income Tax Mon, 17 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467520