https://www.taxtmi.com/caselaws?id=792586 Validity of reassessment notices is examined in the context of the pre-2021 and post-2021 regimes, including the effect of section 3(1) of TOLA, the executive extension of limitation, and the Finance Act, 2021 substitution of reassessment provisions without savings. The text also addresses whether the proviso to substituted section 149(1) can operate as a savings clause, the validity of notifications issued under TOLA, and the attempted conversion of old section 148 notices into notices under newly inserted section 148A(b). It further notes a Special Leave Petition filed with 715 days' delay, which the Court treated as unexplained, and records dismissal on delay as well as on merits. en-us Tue, 26 May 2026 00:00:00 +0530 Sat, 30 May 2026 08:29:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792586 Validity of reassessment notices is examined in the context of the pre-2021 and post-2021 regimes, including the effect of section 3(1) of TOLA, the executive extension of limitation, and the Finance Act, 2021 substitution of reassessment provisions without savings. The text also addresses whether the proviso to substituted section 149(1) can operate as a savings clause, the validity of notifications issued under TOLA, and the attempted conversion of old section 148 notices into notices under newly inserted section 148A(b). It further notes a Special Leave Petition filed with 715 days' delay, which the Court treated as unexplained, and records dismissal on delay as well as on merits. Case-Laws Income Tax Tue, 26 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792586