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    <title>2026 (5) TMI 1423 - BOMBAY HIGH COURT</title>
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    <description>An earlier judgment attracts the extended assessment machinery only if it contains a finding or direction necessary for disposal of the matter; incidental observations are insufficient. The Bombay HC held that the prior judgment merely stated that the Revenue could proceed in accordance with law against the successor entity and did not ermine liability on merits, so it could not justify later action under the extended provisions. It further held that notices under sections 143(2) and 142(1) were issued beyond the statutory limitation period, and the time bar could not be overcome by relying on the earlier judgment or by treating the proceedings as a fresh opportunity. The impugned notices and consequential proceedings were quashed.</description>
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      <title>2026 (5) TMI 1423 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=792221</link>
      <description>An earlier judgment attracts the extended assessment machinery only if it contains a finding or direction necessary for disposal of the matter; incidental observations are insufficient. The Bombay HC held that the prior judgment merely stated that the Revenue could proceed in accordance with law against the successor entity and did not ermine liability on merits, so it could not justify later action under the extended provisions. It further held that notices under sections 143(2) and 142(1) were issued beyond the statutory limitation period, and the time bar could not be overcome by relying on the earlier judgment or by treating the proceedings as a fresh opportunity. The impugned notices and consequential proceedings were quashed.</description>
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