https://www.taxtmi.com/caselaws?id=797295 Reassessment for Assessment Year 2015-16 was time-barred because the first proviso to Section 149(1) preserves the pre-amendment limitation restriction for years up to Assessment Year 2021-22. The applicable six-year period expired on 31 March 2022. The fifth and sixth provisos, excluding time allowed or extended for a response under Section 148A(b), operate within the amended three-year and ten-year framework and do not enlarge the first-proviso restriction. As no extension to respond under Section 148A(b) was sought, the subsequent Section 148 notice was beyond limitation. A non-speaking special leave petition dismissal does not confirm lower-court reasoning or trigger merger. en-us Fri, 07 Aug 2026 00:00:00 +0530 Thu, 20 Aug 2026 08:14:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797295 Reassessment for Assessment Year 2015-16 was time-barred because the first proviso to Section 149(1) preserves the pre-amendment limitation restriction for years up to Assessment Year 2021-22. The applicable six-year period expired on 31 March 2022. The fifth and sixth provisos, excluding time allowed or extended for a response under Section 148A(b), operate within the amended three-year and ten-year framework and do not enlarge the first-proviso restriction. As no extension to respond under Section 148A(b) was sought, the subsequent Section 148 notice was beyond limitation. A non-speaking special leave petition dismissal does not confirm lower-court reasoning or trigger merger. Case-Laws Income Tax Fri, 07 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797295