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    <title>2026 (5) TMI 1624 - ITAT DELHI</title>
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    <description>A reassessment initiated under section 147 following service of notice under section 148 must be completed within the limitation period prescribed by section 153(2), counted from the end of the financial year in which the notice is served. On the admitted dates, the reassessments were completed after the permissible period, so the limitation objection succeeded and the reassessment orders were quashed as time-barred. The merits-based grounds were not examined because they had become academic after the jurisdictional defect on limitation was established.</description>
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