https://www.taxtmi.com/caselaws?id=469735 The validity of a section 148 notice must be tested under the law in force on the date of issue. For assessment year 2015-16, the pre-amendment limitation under section 149(1) had expired on 31.03.2022, and the first proviso to section 149(1), as interpreted by the SC, barred reopening of a year already outside the earlier six-year period. Time excluded under section 148A(b) did not save a notice that was already beyond the permissible limit. The notice dated 01.04.2022 was therefore held time-barred and invalid, and the reassessment and addition were quashed; merits were left open. en-us Tue, 27 Jan 2026 00:00:00 +0530 Fri, 03 Jul 2026 13:12:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469735 The validity of a section 148 notice must be tested under the law in force on the date of issue. For assessment year 2015-16, the pre-amendment limitation under section 149(1) had expired on 31.03.2022, and the first proviso to section 149(1), as interpreted by the SC, barred reopening of a year already outside the earlier six-year period. Time excluded under section 148A(b) did not save a notice that was already beyond the permissible limit. The notice dated 01.04.2022 was therefore held time-barred and invalid, and the reassessment and addition were quashed; merits were left open. Case-Laws Income Tax Tue, 27 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469735