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    <title>2025 (11) TMI 2041 - ITAT VISAKHAPATNAM</title>
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    <description>Reassessment for assessment year 2015-16 was stated to be barred because the six-year limitation period under the former regime expired on 31 March 2022. The relaxation framework under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 did not extend time for a notice issued after that expiry. Supreme Court rulings were identified as requiring reassessment notices for that year issued on or after 1 April 2021 to be dropped. Consequently, a notice issued under section 148 on 3 April 2022 was described as time-barred, depriving the reassessment proceedings of jurisdiction and requiring the assessment under section 147 to be quashed.</description>
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      <description>Reassessment for assessment year 2015-16 was stated to be barred because the six-year limitation period under the former regime expired on 31 March 2022. The relaxation framework under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 did not extend time for a notice issued after that expiry. Supreme Court rulings were identified as requiring reassessment notices for that year issued on or after 1 April 2021 to be dropped. Consequently, a notice issued under section 148 on 3 April 2022 was described as time-barred, depriving the reassessment proceedings of jurisdiction and requiring the assessment under section 147 to be quashed.</description>
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