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    <title>2025 (12) TMI 1870 - ITAT AHMEDABAD</title>
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    <description>Reassessment notices under Sections 147, 148, 148A and 149 of the Income-tax Act, 1961 must comply with the applicable limitation framework during the transition from the former reassessment regime to Section 148A. The Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 could preserve only the surviving limitation period and could not validate a notice that was already time-barred when issued. For notices issued under the deemed Section 148A(b) framework, the Assessing Officer had to complete proceedings within the balance period available on 30 June 2021. Notices issued after those applicable periods, together with consequential reassessment proceedings, were therefore described as invalid and without jurisdiction.</description>
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    <pubDate>Wed, 24 Dec 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=470074</link>
      <description>Reassessment notices under Sections 147, 148, 148A and 149 of the Income-tax Act, 1961 must comply with the applicable limitation framework during the transition from the former reassessment regime to Section 148A. The Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 could preserve only the surviving limitation period and could not validate a notice that was already time-barred when issued. For notices issued under the deemed Section 148A(b) framework, the Assessing Officer had to complete proceedings within the balance period available on 30 June 2021. Notices issued after those applicable periods, together with consequential reassessment proceedings, were therefore described as invalid and without jurisdiction.</description>
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