https://www.taxtmi.com/caselaws?id=469151 A notice under section 148 issued on 07.04.2022 for assessment year 2015-16 was analysed against the unamended six-year limitation period, which expired on 31.03.2022. The commentary applies the transition principle from the old reassessment regime to the amended regime and states that, for assessment years up to 2021-22, a post-amendment notice is valid only if the earlier limitation period had not already expired on the date of issue. As the notice was issued after expiry of the prescribed period, it was treated as incapable of conferring jurisdiction to reopen the assessment, rendering the reassessment proceedings without jurisdiction and the notice time-barred. en-us Thu, 10 Jul 2025 00:00:00 +0530 Thu, 04 Jun 2026 21:14:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469151 A notice under section 148 issued on 07.04.2022 for assessment year 2015-16 was analysed against the unamended six-year limitation period, which expired on 31.03.2022. The commentary applies the transition principle from the old reassessment regime to the amended regime and states that, for assessment years up to 2021-22, a post-amendment notice is valid only if the earlier limitation period had not already expired on the date of issue. As the notice was issued after expiry of the prescribed period, it was treated as incapable of conferring jurisdiction to reopen the assessment, rendering the reassessment proceedings without jurisdiction and the notice time-barred. Case-Laws Income Tax Thu, 10 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469151