https://www.taxtmi.com/caselaws?id=467646 Reassessment notices were analysed under the substituted reassessment regime and TOLA. For assessment year 2015-16, the notice issued on 31 July 2022 was beyond the six-year outer limit that had expired on 31 March 2022, and TOLA did not extend limitation further; the reopening was therefore barred by limitation. For assessment year 2017-18, the notice was issued beyond three years from the end of the year, so prior approval of the higher specified authority was required, but approval from the Principal Commissioner was not competent; the reopening was therefore jurisdictionally defective. en-us Mon, 17 Feb 2025 00:00:00 +0530 Fri, 27 Mar 2026 19:52:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467646 Reassessment notices were analysed under the substituted reassessment regime and TOLA. For assessment year 2015-16, the notice issued on 31 July 2022 was beyond the six-year outer limit that had expired on 31 March 2022, and TOLA did not extend limitation further; the reopening was therefore barred by limitation. For assessment year 2017-18, the notice was issued beyond three years from the end of the year, so prior approval of the higher specified authority was required, but approval from the Principal Commissioner was not competent; the reopening was therefore jurisdictionally defective. Case-Laws Income Tax Mon, 17 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467646