https://www.taxtmi.com/caselaws?id=795198 Reassessment notices for assessment years beginning on or before 1 April 2021 remain subject to the pre-Finance Act 2021 limitation regime under the first proviso to section 149(1). A notice issued beyond six years from the end of the relevant assessment year is time-barred, rendering the reassessment void. An estimated profit addition from the sale of investments is also unsustainable where the investments were recorded and accepted in earlier assessments, sale transactions are supported by documentation and banking receipts, and no incriminating material, cash trail, adverse statement, or other evidence establishes accommodation entries. Conjecture cannot displace substantiated transactions. en-us Fri, 10 Jul 2026 00:00:00 +0530 Sat, 18 Jul 2026 08:27:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795198 Reassessment notices for assessment years beginning on or before 1 April 2021 remain subject to the pre-Finance Act 2021 limitation regime under the first proviso to section 149(1). A notice issued beyond six years from the end of the relevant assessment year is time-barred, rendering the reassessment void. An estimated profit addition from the sale of investments is also unsustainable where the investments were recorded and accepted in earlier assessments, sale transactions are supported by documentation and banking receipts, and no incriminating material, cash trail, adverse statement, or other evidence establishes accommodation entries. Conjecture cannot displace substantiated transactions. Case-Laws Income Tax Fri, 10 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795198