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    <title>2026 (5) TMI 1395 - ITAT DELHI</title>
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    <description>A reassessment notice issued on or after 01.04.2021 must be tested under the new reassessment regime; where a notice claimed to be dated 31.03.2021 was actually issued on 01.04.2021, the reopening under the old scheme could not be sustained, and the reassessment for that year was quashed. The remaining reassessments also failed because the section 151 sanctions were recorded mechanically without due application of mind, and those approvals could not support reopening. All reassessment proceedings were therefore invalid, and the merits became academic.</description>
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    <pubDate>Wed, 29 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 1395 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=792193</link>
      <description>A reassessment notice issued on or after 01.04.2021 must be tested under the new reassessment regime; where a notice claimed to be dated 31.03.2021 was actually issued on 01.04.2021, the reopening under the old scheme could not be sustained, and the reassessment for that year was quashed. The remaining reassessments also failed because the section 151 sanctions were recorded mechanically without due application of mind, and those approvals could not support reopening. All reassessment proceedings were therefore invalid, and the merits became academic.</description>
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