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    <title>2026 (5) TMI 472 - ITAT AHMEDABAD</title>
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    <description>A reassessment notice for Assessment Year 2015-16 issued on or after 01.04.2021 was held time-barred and void, because the limitation defect was jurisdictional and could not be cured by later steps under the reassessment scheme. The subsequent notice under section 148A, the order under section 148A(d), and the reassessment order all failed with the original notice, since the transitional deeming fiction did not revive a notice already barred by limitation. As a result, the reassessment proceedings and resulting additions were quashed, and the merits of the additions were left unexamined as academic.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791270</link>
      <description>A reassessment notice for Assessment Year 2015-16 issued on or after 01.04.2021 was held time-barred and void, because the limitation defect was jurisdictional and could not be cured by later steps under the reassessment scheme. The subsequent notice under section 148A, the order under section 148A(d), and the reassessment order all failed with the original notice, since the transitional deeming fiction did not revive a notice already barred by limitation. As a result, the reassessment proceedings and resulting additions were quashed, and the merits of the additions were left unexamined as academic.</description>
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