https://www.taxtmi.com/caselaws?id=470832 Reassessment jurisdiction cannot rest on the date printed on a section 148 notice where portal records show that the notice was made available for communication only later. Issuance occurs when the notice is dispatched or made available for delivery. Where portal issuance occurred on 1 April 2021, the reassessment was governed by the statutory regime then in force, including the prescribed pre-notice procedure. Non-compliance with that procedure and issuance beyond the applicable limitation period invalidated the assumption of reassessment jurisdiction, rendering the consequential assessment proceedings void ab initio. en-us Wed, 26 Mar 2025 00:00:00 +0530 Mon, 10 Aug 2026 21:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470832 Reassessment jurisdiction cannot rest on the date printed on a section 148 notice where portal records show that the notice was made available for communication only later. Issuance occurs when the notice is dispatched or made available for delivery. Where portal issuance occurred on 1 April 2021, the reassessment was governed by the statutory regime then in force, including the prescribed pre-notice procedure. Non-compliance with that procedure and issuance beyond the applicable limitation period invalidated the assumption of reassessment jurisdiction, rendering the consequential assessment proceedings void ab initio. Case-Laws Income Tax Wed, 26 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470832