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    <description>Reassessment limitation under the substituted regime was tested against the relaxation under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. For assessment year 2015-16, a reassessment notice issued on 16 April 2021 was found to fall outside the surviving limitation period, as the protected window under TOLA did not extend to that notice. Relying on the Supreme Court position in Rajeev Bansal and the Revenue&#039;s concession there, the reassessment initiation was treated as time-barred, and the consequential reassessment proceedings and assessment order were held unsustainable and quashed.</description>
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