https://www.taxtmi.com/caselaws?id=796505 The first proviso to Section 149(1) bars reassessment notices for assessment years beginning on or before 1 April 2021 if they were already time-barred under the erstwhile limitation regime. For assessment year 2015-16, the former six-year limitation expired on 31 March 2022, making the Section 148 notice issued thereafter invalid. Compliance with Section 148A procedures and exclusions or extensions under the erstwhile third and fourth provisos to Section 149(1) cannot override the first proviso or revive a barred notice. The reassessment order was therefore quashed. en-us Thu, 02 Jul 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796505 The first proviso to Section 149(1) bars reassessment notices for assessment years beginning on or before 1 April 2021 if they were already time-barred under the erstwhile limitation regime. For assessment year 2015-16, the former six-year limitation expired on 31 March 2022, making the Section 148 notice issued thereafter invalid. Compliance with Section 148A procedures and exclusions or extensions under the erstwhile third and fourth provisos to Section 149(1) cannot override the first proviso or revive a barred notice. The reassessment order was therefore quashed. Case-Laws Income Tax Thu, 02 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796505