https://www.taxtmi.com/caselaws?id=470631 Reassessment notices issued after the Finance Act, 2021 substituted regime took effect must comply with the revised limitation provisions. Notices issued under the former Section 148 after 1 April 2021 were to be treated as Section 148A show-cause notices while preserving statutory defences under the new framework. Reopening beyond three years was restricted to cases satisfying the prescribed condition concerning income represented in the form of an asset. The analysis rejects the CBDT Instruction's travel-back approach where it would permit reassessment contrary to the substituted limitation regime, rendering notices for AYs 2016-17 and 2017-18 time-barred. en-us Tue, 25 Mar 2025 00:00:00 +0530 Sat, 01 Aug 2026 19:57:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470631 Reassessment notices issued after the Finance Act, 2021 substituted regime took effect must comply with the revised limitation provisions. Notices issued under the former Section 148 after 1 April 2021 were to be treated as Section 148A show-cause notices while preserving statutory defences under the new framework. Reopening beyond three years was restricted to cases satisfying the prescribed condition concerning income represented in the form of an asset. The analysis rejects the CBDT Instruction's travel-back approach where it would permit reassessment contrary to the substituted limitation regime, rendering notices for AYs 2016-17 and 2017-18 time-barred. Case-Laws Income Tax Tue, 25 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470631