https://www.taxtmi.com/caselaws?id=795598 The first proviso to Section 149(1) preserves the limitation period under the erstwhile reassessment regime for assessment years up to 2021-22 and prevents the substituted ten-year period from reviving matters already time-barred. For Assessment Year 2016-17, the prior-law deadline for issuing reassessment notice expired on 31 March 2023. The phrase "at that time" refers to the date of issuing the notice. Search-related information and the extended period contemplated under Section 153C do not override the limitation preserved by the proviso. Accordingly, a Section 148 notice issued on 31 March 2024 for that assessment year was invalid as barred by limitation. en-us Wed, 17 Jun 2026 00:00:00 +0530 Fri, 24 Jul 2026 08:36:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795598 The first proviso to Section 149(1) preserves the limitation period under the erstwhile reassessment regime for assessment years up to 2021-22 and prevents the substituted ten-year period from reviving matters already time-barred. For Assessment Year 2016-17, the prior-law deadline for issuing reassessment notice expired on 31 March 2023. The phrase "at that time" refers to the date of issuing the notice. Search-related information and the extended period contemplated under Section 153C do not override the limitation preserved by the proviso. Accordingly, a Section 148 notice issued on 31 March 2024 for that assessment year was invalid as barred by limitation. Case-Laws Income Tax Wed, 17 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795598