https://www.taxtmi.com/caselaws?id=792822 Reopening under Section 148 was examined against the limitation applicable to Assessment Year 2015-16. The Tribunal noted that the notice was issued on 04.04.2022 after proceedings under Section 148A(b) and an order under Section 148A(d), but the first proviso to Section 149(1) controlled because the relevant assessment year had already crossed the earlier six-year outer limit. It applied the settled principle that the amended longer limitation cannot revive a notice already barred under the pre-amendment regime, and that the later stages under Sections 148A(b) and 148A(d) do not extend limitation once it has expired. The notice was held time-barred and liable to be quashed. en-us Thu, 14 May 2026 00:00:00 +0530 Thu, 04 Jun 2026 08:37:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792822 Reopening under Section 148 was examined against the limitation applicable to Assessment Year 2015-16. The Tribunal noted that the notice was issued on 04.04.2022 after proceedings under Section 148A(b) and an order under Section 148A(d), but the first proviso to Section 149(1) controlled because the relevant assessment year had already crossed the earlier six-year outer limit. It applied the settled principle that the amended longer limitation cannot revive a notice already barred under the pre-amendment regime, and that the later stages under Sections 148A(b) and 148A(d) do not extend limitation once it has expired. The notice was held time-barred and liable to be quashed. Case-Laws Income Tax Thu, 14 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792822