https://www.taxtmi.com/caselaws?id=799837 The first proviso to Section 149(1)(b) retains the pre-amendment limitation regime for assessment years beginning on or before 1 April 2021. For Assessment Year 2015-16, the six-year period expired on 31 March 2022. The amended extended limitation period cannot operate retrospectively to revive a reassessment notice already barred under the earlier regime. Exclusions of time connected with Section 148A proceedings do not override the proviso's limitation restriction. Consequently, the notice issued on 7 April 2022 was time-barred, and the consequential reassessment order was quashed. en-us Wed, 19 Aug 2026 00:00:00 +0530 Mon, 28 Sep 2026 08:12:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799837 The first proviso to Section 149(1)(b) retains the pre-amendment limitation regime for assessment years beginning on or before 1 April 2021. For Assessment Year 2015-16, the six-year period expired on 31 March 2022. The amended extended limitation period cannot operate retrospectively to revive a reassessment notice already barred under the earlier regime. Exclusions of time connected with Section 148A proceedings do not override the proviso's limitation restriction. Consequently, the notice issued on 7 April 2022 was time-barred, and the consequential reassessment order was quashed. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799837