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    <title>2026 (6) TMI 739 - MADRAS HIGH COURT</title>
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    <description>Reassessment under the amended Income-tax Act regime was treated as time-barred only if the statutory period under Section 149 was exceeded; the Court held that the time consumed between the Section 148A(b) notice and the assessee&#039;s reply is excluded for limitation, so the proceedings were within time. On merits, reopening was upheld because the alleged escaped receipts were not included in the return or earlier scrutiny assessment, and prima facie material showed non-disclosure and related discrepancies. Audit-related material did not by itself create a jurisdictional defect where the reassessment machinery was otherwise lawfully invoked. The writ challenge failed and the reassessment notice and order were sustained.</description>
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    <pubDate>Wed, 03 Jun 2026 00:00:00 +0530</pubDate>
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      <title>2026 (6) TMI 739 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=793358</link>
      <description>Reassessment under the amended Income-tax Act regime was treated as time-barred only if the statutory period under Section 149 was exceeded; the Court held that the time consumed between the Section 148A(b) notice and the assessee&#039;s reply is excluded for limitation, so the proceedings were within time. On merits, reopening was upheld because the alleged escaped receipts were not included in the return or earlier scrutiny assessment, and prima facie material showed non-disclosure and related discrepancies. Audit-related material did not by itself create a jurisdictional defect where the reassessment machinery was otherwise lawfully invoked. The writ challenge failed and the reassessment notice and order were sustained.</description>
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