https://www.taxtmi.com/caselaws?id=791985 The amended limitation regime under section 149(1) of the Income-tax Act, 1961, read with the first proviso preserving the earlier outer limit for assessment years before 2021-22, required the notice period to be tested against the pre-amendment six-year limit. For assessment year 2015-16, that limit expired on 31.03.2022. A notice under section 148 issued on 01.04.2022 was therefore beyond time, and the third proviso could not save it because the notice had already failed the threshold requirement of timeliness. The reassessment founded on that notice was invalid and the addition was deleted. en-us Mon, 04 May 2026 00:00:00 +0530 Thu, 21 May 2026 08:30:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791985 The amended limitation regime under section 149(1) of the Income-tax Act, 1961, read with the first proviso preserving the earlier outer limit for assessment years before 2021-22, required the notice period to be tested against the pre-amendment six-year limit. For assessment year 2015-16, that limit expired on 31.03.2022. A notice under section 148 issued on 01.04.2022 was therefore beyond time, and the third proviso could not save it because the notice had already failed the threshold requirement of timeliness. The reassessment founded on that notice was invalid and the addition was deleted. Case-Laws Income Tax Mon, 04 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791985