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    <title>Extended reassessment limitation operates prospectively, so a notice issued after six years was held time-barred.</title>
    <link>https://www.taxtmi.com/highlights?id=100634</link>
    <description>A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee&#039;s cross objection was allowed, and the Revenue&#039;s appeal on merits failed.</description>
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    <pubDate>Wed, 10 Jun 2026 07:26:55 +0530</pubDate>
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      <title>Extended reassessment limitation operates prospectively, so a notice issued after six years was held time-barred.</title>
      <link>https://www.taxtmi.com/highlights?id=100634</link>
      <description>A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee&#039;s cross objection was allowed, and the Revenue&#039;s appeal on merits failed.</description>
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      <pubDate>Wed, 10 Jun 2026 07:26:55 +0530</pubDate>
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