https://www.taxtmi.com/caselaws?id=791198 For an assessment year governed by the pre-01.04.2021 limitation regime, a notice under section 148 cannot be sustained if the six-year period had already expired on the date of issue. The Tribunal admitted the jurisdictional challenge as a pure question of law on the existing record and held that the later amended limitation structure could not revive a time-barred notice. Although the section 148A(b) show-cause notice was issued within time, the section 148 notice itself was beyond limitation and was quashed. The reassessment order consequently could not survive, and the remaining grounds became infructuous. en-us Fri, 17 Apr 2026 00:00:00 +0530 Wed, 06 May 2026 12:29:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791198 For an assessment year governed by the pre-01.04.2021 limitation regime, a notice under section 148 cannot be sustained if the six-year period had already expired on the date of issue. The Tribunal admitted the jurisdictional challenge as a pure question of law on the existing record and held that the later amended limitation structure could not revive a time-barred notice. Although the section 148A(b) show-cause notice was issued within time, the section 148 notice itself was beyond limitation and was quashed. The reassessment order consequently could not survive, and the remaining grounds became infructuous. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791198