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    <title>2025 (10) TMI 1407 - ITAT KOLKATA</title>
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    <description>Reassessment notices under section 148 were held to be time-barred because they were issued after the extended outer limitation period under the substituted reassessment regime and the TOLA relaxation. Applying the Supreme Court&#039;s guidance on the interaction between the amended reassessment provisions and the relaxation framework in Rajeev Bansal, the Tribunal found that the surviving time to issue notice had already expired. As a result, the notices could not confer jurisdiction to reopen the assessments and were quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468501</link>
      <description>Reassessment notices under section 148 were held to be time-barred because they were issued after the extended outer limitation period under the substituted reassessment regime and the TOLA relaxation. Applying the Supreme Court&#039;s guidance on the interaction between the amended reassessment provisions and the relaxation framework in Rajeev Bansal, the Tribunal found that the surviving time to issue notice had already expired. As a result, the notices could not confer jurisdiction to reopen the assessments and were quashed.</description>
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