https://www.taxtmi.com/caselaws?id=468521 A reassessment notice issued after 1 April 2021 must be tested under the substituted reassessment regime, with TOLA relaxation applying only to the extent recognised by the Supreme Court. On the stated facts, a notice under section 148 issued on 19 July 2022 for assessment year 2013-14 was beyond the surviving limitation period and could not be sustained. The Tribunal treated the issue as governed by binding Supreme Court principles on transition-period notices and held that the notice was without jurisdiction and liable to be quashed as barred by limitation. en-us Thu, 18 Sep 2025 00:00:00 +0530 Mon, 11 May 2026 14:58:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468521 A reassessment notice issued after 1 April 2021 must be tested under the substituted reassessment regime, with TOLA relaxation applying only to the extent recognised by the Supreme Court. On the stated facts, a notice under section 148 issued on 19 July 2022 for assessment year 2013-14 was beyond the surviving limitation period and could not be sustained. The Tribunal treated the issue as governed by binding Supreme Court principles on transition-period notices and held that the notice was without jurisdiction and liable to be quashed as barred by limitation. Case-Laws Income Tax Thu, 18 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468521