https://www.taxtmi.com/caselaws?id=793656 For assessment years beginning on or before 01.04.2021, the validity of reopening must be tested under the unamended limitation regime preserved by the first proviso to section 149(1). A notice under section 148 issued after expiry of the then-applicable six-year period is time-barred, and the exclusion for time taken in responding to section 148A(b) cannot revive a reopening already barred by that outer limit. Applying that principle, the notice dated 07.04.2022 for AY 2015-16 was invalid, and the reassessment proceedings and consequential assessment order could not survive. en-us Wed, 17 Jun 2026 00:00:00 +0530 Sat, 20 Jun 2026 08:04:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793656 For assessment years beginning on or before 01.04.2021, the validity of reopening must be tested under the unamended limitation regime preserved by the first proviso to section 149(1). A notice under section 148 issued after expiry of the then-applicable six-year period is time-barred, and the exclusion for time taken in responding to section 148A(b) cannot revive a reopening already barred by that outer limit. Applying that principle, the notice dated 07.04.2022 for AY 2015-16 was invalid, and the reassessment proceedings and consequential assessment order could not survive. Case-Laws Income Tax Wed, 17 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793656