https://www.taxtmi.com/caselaws?id=795288 Time-barred reassessment notices issued under the pre-2021 regime raised questions about whether Section 3(1) of TOLA permitted executive extension of limitation after the Finance Act 2021 repealed and substituted the reassessment provisions without a savings clause. The proviso to substituted Section 149(1) was considered not to preserve the prior regime, and Notifications No. 20/2021 and 38/2021 issued under TOLA were identified as ultra vires. Old Section 148 notices were also considered for treatment or conversion as notices under Section 148A(b). The Special Leave Petitions were dismissed because of unexplained inordinate delay in filing. en-us Thu, 16 Jul 2026 00:00:00 +0530 Mon, 20 Jul 2026 09:37:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795288 Time-barred reassessment notices issued under the pre-2021 regime raised questions about whether Section 3(1) of TOLA permitted executive extension of limitation after the Finance Act 2021 repealed and substituted the reassessment provisions without a savings clause. The proviso to substituted Section 149(1) was considered not to preserve the prior regime, and Notifications No. 20/2021 and 38/2021 issued under TOLA were identified as ultra vires. Old Section 148 notices were also considered for treatment or conversion as notices under Section 148A(b). The Special Leave Petitions were dismissed because of unexplained inordinate delay in filing. Case-Laws Income Tax Thu, 16 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795288