https://www.taxtmi.com/caselaws?id=469172 For assessment years beginning on or before 01.04.2021, a notice under section 148 cannot be sustained under the amended reassessment regime if the reopening was already time-barred under the unamended section 149 when the new law took effect. Applying the first proviso to section 149(1), the notice issued on 06.04.2022 for assessment year 2015-16 was beyond the then-applicable limitation, which expired on 31.03.2022. The reassessment framed under sections 147 and 144 was therefore unsustainable and was set aside as invalid in law. en-us Thu, 26 Feb 2026 00:00:00 +0530 Sat, 06 Jun 2026 20:01:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469172 For assessment years beginning on or before 01.04.2021, a notice under section 148 cannot be sustained under the amended reassessment regime if the reopening was already time-barred under the unamended section 149 when the new law took effect. Applying the first proviso to section 149(1), the notice issued on 06.04.2022 for assessment year 2015-16 was beyond the then-applicable limitation, which expired on 31.03.2022. The reassessment framed under sections 147 and 144 was therefore unsustainable and was set aside as invalid in law. Case-Laws Income Tax Thu, 26 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469172