https://www.taxtmi.com/caselaws?id=795198 For assessment years beginning on or before 1 April 2021, the note explains that the first proviso to Section 149(1) preserves the earlier limitation regime; a reassessment notice issued beyond six years from the end of the relevant assessment year is therefore time-barred and invalid. It further states that an estimated profit addition from investment sale proceeds requires substantive evidence. Where investments were recorded and accepted in earlier assessments, and sales are supported by documents and banking records, conjecture without incriminating material, a cash trail, or other linkage cannot sustain an addition. 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 For assessment years beginning on or before 1 April 2021, the note explains that the first proviso to Section 149(1) preserves the earlier limitation regime; a reassessment notice issued beyond six years from the end of the relevant assessment year is therefore time-barred and invalid. It further states that an estimated profit addition from investment sale proceeds requires substantive evidence. Where investments were recorded and accepted in earlier assessments, and sales are supported by documents and banking records, conjecture without incriminating material, a cash trail, or other linkage cannot sustain an addition. Case-Laws Income Tax Fri, 10 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795198