https://www.taxtmi.com/caselaws?id=789908 Proceedings under section 201(1) for earlier assessment years were held to be time-barred because the first effective show-cause notice came after the limitation period had already expired, and earlier communications were treated only as information requests. The saving proviso to section 201(3) was held to apply only to proceedings that were actually pending within its stated window; it did not revive matters already barred by time. The Tribunal's view that the initiation was beyond the permissible period was therefore left undisturbed, and the Revenue's challenge failed. en-us Wed, 01 Apr 2026 00:00:00 +0530 Thu, 16 Apr 2026 08:34:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789908 Proceedings under section 201(1) for earlier assessment years were held to be time-barred because the first effective show-cause notice came after the limitation period had already expired, and earlier communications were treated only as information requests. The saving proviso to section 201(3) was held to apply only to proceedings that were actually pending within its stated window; it did not revive matters already barred by time. The Tribunal's view that the initiation was beyond the permissible period was therefore left undisturbed, and the Revenue's challenge failed. Case-Laws Income Tax Wed, 01 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789908