https://www.taxtmi.com/caselaws?id=797089 Requisition proceedings under Section 132A governed by the pre-existing Section 153A assessment regime had to be initiated and completed within the limitation prescribed by Section 153B. Expiry of that period could not be circumvented by invoking the reassessment procedure under Sections 148A and 148 introduced from 1 April 2021. The relevant Explanation to Section 148 applied only to searches or requisitions conducted on or after that date. A challenge to the statutory procedure was distinct from an objection to territorial jurisdiction under Section 124(3). Consequently, the reassessment notice and proceedings were invalid, and the penalty founded on the resulting reassessment could not survive. en-us Thu, 13 Aug 2026 00:00:00 +0530 Mon, 17 Aug 2026 08:38:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797089 Requisition proceedings under Section 132A governed by the pre-existing Section 153A assessment regime had to be initiated and completed within the limitation prescribed by Section 153B. Expiry of that period could not be circumvented by invoking the reassessment procedure under Sections 148A and 148 introduced from 1 April 2021. The relevant Explanation to Section 148 applied only to searches or requisitions conducted on or after that date. A challenge to the statutory procedure was distinct from an objection to territorial jurisdiction under Section 124(3). Consequently, the reassessment notice and proceedings were invalid, and the penalty founded on the resulting reassessment could not survive. Case-Laws Income Tax Thu, 13 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797089