https://www.taxtmi.com/caselaws?id=796170 A notice under Section 148 for Assessment Year 2015-16 was beyond the limitation period applicable under the pre-amendment regime, which expired on 31 March 2022. The first proviso to Section 149(1), inserted by the Finance Act, 2021, preserves that restriction for past assessment years. The fifth and sixth provisos, which provide exclusion and extension mechanisms within the amended three-year or ten-year framework, cannot extend the limitation preserved by the first proviso. Consequently, the notice dated 7 April 2022 was time-barred, invalid, and incapable of conferring jurisdiction for reassessment. en-us Fri, 12 Jun 2026 00:00:00 +0530 Sat, 01 Aug 2026 08:34:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796170 A notice under Section 148 for Assessment Year 2015-16 was beyond the limitation period applicable under the pre-amendment regime, which expired on 31 March 2022. The first proviso to Section 149(1), inserted by the Finance Act, 2021, preserves that restriction for past assessment years. The fifth and sixth provisos, which provide exclusion and extension mechanisms within the amended three-year or ten-year framework, cannot extend the limitation preserved by the first proviso. Consequently, the notice dated 7 April 2022 was time-barred, invalid, and incapable of conferring jurisdiction for reassessment. Case-Laws Income Tax Fri, 12 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796170