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    <title>2026 (6) TMI 827 - ITAT HYDERABAD</title>
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    <description>A reassessment notice under section 148 for assessment year 2015-16 was held to be time-barred because it was issued beyond the limitation period reflected in the unamended section 149(1)(b). The amended first proviso to section 149(1) was read as preserving the earlier bar for assessment years beginning on or before 01.04.2021 where a notice could not have been issued under the pre-amendment regime. The exclusion periods in the fifth and sixth provisos were held not to extend the first proviso&#039;s restriction. As the notice was invalid, the reassessment lacked jurisdiction and the consequential assessment order could not stand.</description>
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      <title>2026 (6) TMI 827 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=793446</link>
      <description>A reassessment notice under section 148 for assessment year 2015-16 was held to be time-barred because it was issued beyond the limitation period reflected in the unamended section 149(1)(b). The amended first proviso to section 149(1) was read as preserving the earlier bar for assessment years beginning on or before 01.04.2021 where a notice could not have been issued under the pre-amendment regime. The exclusion periods in the fifth and sixth provisos were held not to extend the first proviso&#039;s restriction. As the notice was invalid, the reassessment lacked jurisdiction and the consequential assessment order could not stand.</description>
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