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    <title>2025 (9) TMI 1785 - MADRAS HIGH COURT</title>
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    <description>Reassessment under the post-01.04.2021 regime was held invalid where notices were issued beyond the surviving limitation or without the higher approval required by section 151(ii) when escaped income exceeded the statutory threshold and more than three years had elapsed from the end of the relevant assessment year. The court applied the Supreme Court rulings in Ashish Agarwal and Rajeev Bansal to exclude the deemed-show-cause period and response time while computing limitation. Consequential assessment orders and penalty notices based on defective reassessment action were set aside, and the matters were remitted for fresh proceedings after obtaining proper statutory sanction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468372</link>
      <description>Reassessment under the post-01.04.2021 regime was held invalid where notices were issued beyond the surviving limitation or without the higher approval required by section 151(ii) when escaped income exceeded the statutory threshold and more than three years had elapsed from the end of the relevant assessment year. The court applied the Supreme Court rulings in Ashish Agarwal and Rajeev Bansal to exclude the deemed-show-cause period and response time while computing limitation. Consequential assessment orders and penalty notices based on defective reassessment action were set aside, and the matters were remitted for fresh proceedings after obtaining proper statutory sanction.</description>
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