https://www.taxtmi.com/caselaws?id=467550 Reassessment under the amended Finance Act, 2021 framework is barred where, at the time of issuance, the six-year limitation under the pre-amendment regime had already expired for the relevant assessment year. Applying the proviso to section 149(1)(b) and the principle in Union of India v. Rajeev Bansal, notices for past assessment years on or before 1 April 2021 cannot be sustained once the old limitation period has run out. For AY 2016-17, the six-year period had expired before the impugned notice dated 10.04.2023, so the order under section 148A(d) and the notice under section 148 were time-barred and quashed. en-us Thu, 11 Sep 2025 00:00:00 +0530 Mon, 23 Mar 2026 20:37:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467550 Reassessment under the amended Finance Act, 2021 framework is barred where, at the time of issuance, the six-year limitation under the pre-amendment regime had already expired for the relevant assessment year. Applying the proviso to section 149(1)(b) and the principle in Union of India v. Rajeev Bansal, notices for past assessment years on or before 1 April 2021 cannot be sustained once the old limitation period has run out. For AY 2016-17, the six-year period had expired before the impugned notice dated 10.04.2023, so the order under section 148A(d) and the notice under section 148 were time-barred and quashed. Case-Laws Income Tax Thu, 11 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467550