https://www.taxtmi.com/caselaws?id=797852 Reassessment notice under Section 148 issued after expiry of the pre-amendment limitation period is barred where the amended reassessment regime does not revive a time-barred matter. The first proviso to Section 149(1) prevents issuance of a notice that could not have been issued under the earlier limitation provisions. Where the notice concerns the same underlying issue already raised in Section 153C proceedings, reassessment jurisdiction is also unavailable. The Section 148 notice was therefore time-barred and without jurisdiction. en-us Fri, 21 Aug 2026 00:00:00 +0530 Fri, 28 Aug 2026 20:42:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797852 Reassessment notice under Section 148 issued after expiry of the pre-amendment limitation period is barred where the amended reassessment regime does not revive a time-barred matter. The first proviso to Section 149(1) prevents issuance of a notice that could not have been issued under the earlier limitation provisions. Where the notice concerns the same underlying issue already raised in Section 153C proceedings, reassessment jurisdiction is also unavailable. The Section 148 notice was therefore time-barred and without jurisdiction. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797852