https://www.taxtmi.com/caselaws?id=794006 Reopening based on information from a search under section 132 in a third party's case falls within the proviso to section 148A, so the section 148A procedure cannot be used to confer jurisdiction or cure the defect in initiation. Where the alleged escapement is below the monetary threshold required for the extended limitation under section 149(1)(b), the extended period is unavailable and a notice issued after expiry of the normal three-year period is time-barred. The reassessment was therefore quashed on both jurisdictional and limitation grounds. en-us Tue, 23 Jun 2026 00:00:00 +0530 Sat, 27 Jun 2026 08:33:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794006 Reopening based on information from a search under section 132 in a third party's case falls within the proviso to section 148A, so the section 148A procedure cannot be used to confer jurisdiction or cure the defect in initiation. Where the alleged escapement is below the monetary threshold required for the extended limitation under section 149(1)(b), the extended period is unavailable and a notice issued after expiry of the normal three-year period is time-barred. The reassessment was therefore quashed on both jurisdictional and limitation grounds. Case-Laws Income Tax Tue, 23 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794006