https://www.taxtmi.com/caselaws?id=792255 The Tribunal examined whether reassessment notices issued under section 148, after the Ashish Agarwal transitional regime, were barred by limitation. It held that although the original notices were issued within the TOLA period, the fresh notices issued after section 148A(b) proceedings were beyond the last permissible dates under the surviving time principle applied in Ashish Agarwal and Rajeev Bansal, as followed by the jurisdictional High Court. On the admitted dates, the notices for the relevant assessment years were issued after expiry of the limitation period under section 149 and the applicable transitional directions. The notices were therefore time-barred, jurisdiction to reopen failed, and the reassessment orders were liable to be quashed. en-us Wed, 22 Apr 2026 00:00:00 +0530 Tue, 26 May 2026 08:24:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792255 The Tribunal examined whether reassessment notices issued under section 148, after the Ashish Agarwal transitional regime, were barred by limitation. It held that although the original notices were issued within the TOLA period, the fresh notices issued after section 148A(b) proceedings were beyond the last permissible dates under the surviving time principle applied in Ashish Agarwal and Rajeev Bansal, as followed by the jurisdictional High Court. On the admitted dates, the notices for the relevant assessment years were issued after expiry of the limitation period under section 149 and the applicable transitional directions. The notices were therefore time-barred, jurisdiction to reopen failed, and the reassessment orders were liable to be quashed. Case-Laws Income Tax Wed, 22 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792255