https://www.taxtmi.com/caselaws?id=796173 Notice for assessment under the Black Money Act was issued beyond the timeline prescribed by CBDT Guidelines. Information on the undisclosed foreign asset was available to the Department in April 2019 and, at the latest, when reopening reasons were recorded in March 2021. The Guidelines required a section 10(1) notice preferably within 30 days after the relevant previous year, with written reasons and competent-authority approval for delay. No recorded reasons or approval supported the delayed March 2022 notice. As the administrative instructions bound the Revenue, the notice was time-barred and consequential proceedings were null and void. en-us Thu, 16 Jul 2026 00:00:00 +0530 Sat, 01 Aug 2026 08:34:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796173 Notice for assessment under the Black Money Act was issued beyond the timeline prescribed by CBDT Guidelines. Information on the undisclosed foreign asset was available to the Department in April 2019 and, at the latest, when reopening reasons were recorded in March 2021. The Guidelines required a section 10(1) notice preferably within 30 days after the relevant previous year, with written reasons and competent-authority approval for delay. No recorded reasons or approval supported the delayed March 2022 notice. As the administrative instructions bound the Revenue, the notice was time-barred and consequential proceedings were null and void. Case-Laws Income Tax Thu, 16 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796173