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    <title>2026 (7) TMI 618 - ITAT MUMBAI</title>
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    <description>In reassessment proceedings based on deemed notices under the substituted regime, the Revenue had to act within the surviving limitation period after excluding the stayed period, time for furnishing information and material, and the assessee&#039;s reply period; notices issued later were time-barred and invalid. For years beyond three years from the end of the assessment year, prior approval had to be taken from the authority specified under section 151(ii); approval from the Principal Commissioner was insufficient and the defect was jurisdictional. The reassessment notices, section 148A(d) orders, and consequential proceedings were therefore void.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794732</link>
      <description>In reassessment proceedings based on deemed notices under the substituted regime, the Revenue had to act within the surviving limitation period after excluding the stayed period, time for furnishing information and material, and the assessee&#039;s reply period; notices issued later were time-barred and invalid. For years beyond three years from the end of the assessment year, prior approval had to be taken from the authority specified under section 151(ii); approval from the Principal Commissioner was insufficient and the defect was jurisdictional. The reassessment notices, section 148A(d) orders, and consequential proceedings were therefore void.</description>
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      <pubDate>Tue, 07 Jul 2026 00:00:00 +0530</pubDate>
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