https://www.taxtmi.com/caselaws?id=798729 Limitation under the first proviso to section 149(1) retains the pre-amendment reassessment time limit for assessment years beginning on or before 1 April 2021. For assessment year 2015-16, the applicable six-year period ended on 31 March 2022; consequently, a section 148 notice issued on 7 April 2022 was time-barred. The amended extended period does not revive reassessment proceedings already barred by limitation. Later provisos permitting exclusion of time were neither in force on the notice date nor applicable where no additional time to respond under section 148A(b) had been sought. The consequential reassessment was vitiated. en-us Wed, 15 Jul 2026 00:00:00 +0530 Fri, 11 Sep 2026 08:13:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798729 Limitation under the first proviso to section 149(1) retains the pre-amendment reassessment time limit for assessment years beginning on or before 1 April 2021. For assessment year 2015-16, the applicable six-year period ended on 31 March 2022; consequently, a section 148 notice issued on 7 April 2022 was time-barred. The amended extended period does not revive reassessment proceedings already barred by limitation. Later provisos permitting exclusion of time were neither in force on the notice date nor applicable where no additional time to respond under section 148A(b) had been sought. The consequential reassessment was vitiated. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798729