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    <title>2025 (5) TMI 2275 - DELHI HIGH COURT</title>
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    <description>Reassessment under Section 148 for AY 2016-17 was held time-barred because the notice was issued after the six-year limitation period from the end of the relevant assessment year, and after expiry of the period preserved by the proviso to Section 149(1)(b). The court applied the governing limitation framework and held that the reopening could not be sustained once that period had expired on 31.03.2023. As the reassessment notice was invalid, the order under Section 148A(d) and the consequential assessment order based on that reopening were also set aside.</description>
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    <pubDate>Fri, 09 May 2025 00:00:00 +0530</pubDate>
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      <title>2025 (5) TMI 2275 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=468326</link>
      <description>Reassessment under Section 148 for AY 2016-17 was held time-barred because the notice was issued after the six-year limitation period from the end of the relevant assessment year, and after expiry of the period preserved by the proviso to Section 149(1)(b). The court applied the governing limitation framework and held that the reopening could not be sustained once that period had expired on 31.03.2023. As the reassessment notice was invalid, the order under Section 148A(d) and the consequential assessment order based on that reopening were also set aside.</description>
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      <pubDate>Fri, 09 May 2025 00:00:00 +0530</pubDate>
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