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    <title>2026 (5) TMI 320 - ITAT AGRA</title>
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    <description>Reassessment notices under section 148 were issued under the substituted reassessment regime and had to be tested against the transitional relaxation under TOLA and the Supreme Court&#039;s directions on deemed notice and supply of material. On the recorded facts, the notices dated 26.07.2022 and 30.07.2022 were issued beyond the surviving limitation period, rendering them invalid in law. As the notices themselves were time-barred, the reassessment proceedings founded on them could not be sustained and were quashed in all the appeals.</description>
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      <description>Reassessment notices under section 148 were issued under the substituted reassessment regime and had to be tested against the transitional relaxation under TOLA and the Supreme Court&#039;s directions on deemed notice and supply of material. On the recorded facts, the notices dated 26.07.2022 and 30.07.2022 were issued beyond the surviving limitation period, rendering them invalid in law. As the notices themselves were time-barred, the reassessment proceedings founded on them could not be sustained and were quashed in all the appeals.</description>
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