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    <title>2025 (3) TMI 1913 - ITAT MUMBAI</title>
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    <description>A reassessment notice issued under the substituted reassessment regime was held to be time-barred because it was served after the limitation period that remained available even after applying the relaxation under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The governing principle was that TOLA could extend only the surviving statutory deadline, and a notice issued beyond that extended cutoff was without jurisdiction. The reopening therefore failed, the notice was set aside, and the merits were not examined.</description>
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      <title>2025 (3) TMI 1913 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=469938</link>
      <description>A reassessment notice issued under the substituted reassessment regime was held to be time-barred because it was served after the limitation period that remained available even after applying the relaxation under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The governing principle was that TOLA could extend only the surviving statutory deadline, and a notice issued beyond that extended cutoff was without jurisdiction. The reopening therefore failed, the notice was set aside, and the merits were not examined.</description>
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