https://www.taxtmi.com/caselaws?id=472002 Notice under section 148 issued after expiry of the surviving period available under the applicable reassessment framework and extended limitation regime invalidates the reopening and any revision founded on it. For section 263, reassessment initiated specifically to examine an alleged on-money payment constitutes enquiry where that examination is evidenced by the order under section 148A(d). Mere absence of discussion of the issue in the reassessment order does not, by itself, establish that the order is erroneous and prejudicial to the interests of the Revenue under Explanation 2 to section 263. Revisionary action cannot rest on a time-barred reopening or an unsubstantiated allegation of lack of enquiry. en-us Thu, 18 Sep 2025 00:00:00 +0530 Fri, 25 Sep 2026 20:15:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472002 Notice under section 148 issued after expiry of the surviving period available under the applicable reassessment framework and extended limitation regime invalidates the reopening and any revision founded on it. For section 263, reassessment initiated specifically to examine an alleged on-money payment constitutes enquiry where that examination is evidenced by the order under section 148A(d). Mere absence of discussion of the issue in the reassessment order does not, by itself, establish that the order is erroneous and prejudicial to the interests of the Revenue under Explanation 2 to section 263. Revisionary action cannot rest on a time-barred reopening or an unsubstantiated allegation of lack of enquiry. Case-Laws Income Tax Thu, 18 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472002