https://www.taxtmi.com/caselaws?id=793655 A reassessment notice under section 148 was issued after the six-year limit under the unamended section 149(1)(b) had expired. The first proviso to section 149, as introduced by the Finance Act, 2021, barred issuance of a notice where, on the commencement date of the new regime, such notice could not have been issued under the old law. Later exclusion and extension clauses in section 149(1) did not revive a notice already hit by that proviso. Because the foundational notice was invalid and time-barred, the reassessment proceedings and the assessment order based on it could not survive. en-us Wed, 17 Jun 2026 00:00:00 +0530 Sat, 20 Jun 2026 08:04:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793655 A reassessment notice under section 148 was issued after the six-year limit under the unamended section 149(1)(b) had expired. The first proviso to section 149, as introduced by the Finance Act, 2021, barred issuance of a notice where, on the commencement date of the new regime, such notice could not have been issued under the old law. Later exclusion and extension clauses in section 149(1) did not revive a notice already hit by that proviso. Because the foundational notice was invalid and time-barred, the reassessment proceedings and the assessment order based on it could not survive. Case-Laws Income Tax Wed, 17 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793655