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    <title>2026 (2) TMI 1428 - ITAT VISAKHAPATNAM</title>
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    <description>A reassessment notice under section 148 for AY 2015-16 was held time-barred because it was issued after the pre-amended limitation period had expired on 31.03.2022. The first proviso to section 149(1), as amended by the Finance Act, 2021 regime, barred issuance where such notice could not have been issued under the old limitation on the commencement date. The fifth and sixth provisos were held not to extend or revive a notice already barred under the first proviso. As a result, the notice was invalid and the assessment made on its basis was without valid jurisdiction.</description>
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      <title>2026 (2) TMI 1428 - ITAT VISAKHAPATNAM</title>
      <link>https://www.taxtmi.com/caselaws?id=469140</link>
      <description>A reassessment notice under section 148 for AY 2015-16 was held time-barred because it was issued after the pre-amended limitation period had expired on 31.03.2022. The first proviso to section 149(1), as amended by the Finance Act, 2021 regime, barred issuance where such notice could not have been issued under the old limitation on the commencement date. The fifth and sixth provisos were held not to extend or revive a notice already barred under the first proviso. As a result, the notice was invalid and the assessment made on its basis was without valid jurisdiction.</description>
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