https://www.taxtmi.com/caselaws?id=795212 Reassessment notices issued after 1 April 2021 must comply with the amended regime and the mandatory outer limitation for issuing notice under Section 148. For Assessment Year 2015-16, exclusion of the response period under Section 148A(b) and the additional statutory extension fixed the outer date at 9 April 2022; an order under Section 148A(d) and notice issued later were time-barred. The consequential assessment and penalty were therefore quashed. The time allowed to pass an order under Section 148A(d) cannot enlarge the Section 149(1) limitation for issuing a reassessment notice. A Revenue concession in Rajeev Bansal was inapplicable because the proceedings did not rely on the 2020 relaxation legislation. en-us Wed, 08 Jul 2026 00:00:00 +0530 Sat, 18 Jul 2026 08:27:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795212 Reassessment notices issued after 1 April 2021 must comply with the amended regime and the mandatory outer limitation for issuing notice under Section 148. For Assessment Year 2015-16, exclusion of the response period under Section 148A(b) and the additional statutory extension fixed the outer date at 9 April 2022; an order under Section 148A(d) and notice issued later were time-barred. The consequential assessment and penalty were therefore quashed. The time allowed to pass an order under Section 148A(d) cannot enlarge the Section 149(1) limitation for issuing a reassessment notice. A Revenue concession in Rajeev Bansal was inapplicable because the proceedings did not rely on the 2020 relaxation legislation. Case-Laws Income Tax Wed, 08 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795212