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    <title>2025 (9) TMI 1767 - TELANGANA HIGH COURT</title>
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    <description>Reassessment for assessment year 2017-18 was held time-barred because the notice under Section 148 dated 16.04.2024 had to be tested against the limitation law in force on that date and was beyond both the pre-amendment and amended time limits, with no statutory exception shown. Reassessment initiated after 01.04.2021 by the jurisdictional Assessing Officer, rather than through the faceless mechanism, was also held impermissible under the amended framework and binding precedent. The reassessment action therefore failed on limitation and procedure, and the impugned notices and order were not sustained.</description>
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      <title>2025 (9) TMI 1767 - TELANGANA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=467551</link>
      <description>Reassessment for assessment year 2017-18 was held time-barred because the notice under Section 148 dated 16.04.2024 had to be tested against the limitation law in force on that date and was beyond both the pre-amendment and amended time limits, with no statutory exception shown. Reassessment initiated after 01.04.2021 by the jurisdictional Assessing Officer, rather than through the faceless mechanism, was also held impermissible under the amended framework and binding precedent. The reassessment action therefore failed on limitation and procedure, and the impugned notices and order were not sustained.</description>
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