https://www.taxtmi.com/caselaws?id=794727 A reassessment notice must satisfy the limitation regime in force on the date of issue, and a notice issued beyond the permissible period under section 149 cannot be sustained. Here, the ITAT held that the notice dated 04.04.2022 for A.Y. 2015-16 was time-barred, and the time given to respond under section 148A(b) could not be excluded to cure an already invalid notice. As the notice failed the threshold test of limitation, the reassessment proceedings could not survive and the addition made in those proceedings was deleted, with the merits left open. en-us Tue, 07 Jul 2026 00:00:00 +0530 Fri, 10 Jul 2026 07:39:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794727 A reassessment notice must satisfy the limitation regime in force on the date of issue, and a notice issued beyond the permissible period under section 149 cannot be sustained. Here, the ITAT held that the notice dated 04.04.2022 for A.Y. 2015-16 was time-barred, and the time given to respond under section 148A(b) could not be excluded to cure an already invalid notice. As the notice failed the threshold test of limitation, the reassessment proceedings could not survive and the addition made in those proceedings was deleted, with the merits left open. Case-Laws Income Tax Tue, 07 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794727