https://www.taxtmi.com/caselaws?id=469680 A reassessment notice issued under section 148 for assessment year 2015-16 was treated as time-barred because the substituted reassessment regime applied and TOLA could extend time only where the relevant limitation remained protected. The Tribunal noted that, on the facts, the limitation for the assessment year expired on 31.03.2022, so a notice issued on 31.07.2022 fell beyond the surviving limitation period. Since a valid notice within time was necessary to assume jurisdiction, the reassessment proceedings were held unsustainable and the notice invalid. The reassessment order was quashed and the assessee's appeal succeeded. en-us Thu, 24 Jul 2025 00:00:00 +0530 Sat, 27 Jun 2026 22:25:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469680 A reassessment notice issued under section 148 for assessment year 2015-16 was treated as time-barred because the substituted reassessment regime applied and TOLA could extend time only where the relevant limitation remained protected. The Tribunal noted that, on the facts, the limitation for the assessment year expired on 31.03.2022, so a notice issued on 31.07.2022 fell beyond the surviving limitation period. Since a valid notice within time was necessary to assume jurisdiction, the reassessment proceedings were held unsustainable and the notice invalid. The reassessment order was quashed and the assessee's appeal succeeded. Case-Laws Income Tax Thu, 24 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469680