https://www.taxtmi.com/caselaws?id=801394 The first proviso to Section 149(1)(b) preserves the earlier six-year limitation for reassessment notices relating to covered assessment years and operates as an absolute restriction. For Assessment Year 2015-16, that period expired on 31 March 2022; therefore, a notice issued on 12 April 2022 was time-barred. The fifth and sixth provisos, which govern exclusions or extensions when computing the amended limitation periods, cannot enlarge the restriction retained by the first proviso. A time-barred jurisdictional notice invalidates the consequential reassessment. Medical incapacity of the person handling an assessee's legal affairs may constitute sufficient cause for condoning filing delay. en-us Wed, 07 Oct 2026 00:00:00 +0530 Wed, 21 Oct 2026 08:37:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801394 The first proviso to Section 149(1)(b) preserves the earlier six-year limitation for reassessment notices relating to covered assessment years and operates as an absolute restriction. For Assessment Year 2015-16, that period expired on 31 March 2022; therefore, a notice issued on 12 April 2022 was time-barred. The fifth and sixth provisos, which govern exclusions or extensions when computing the amended limitation periods, cannot enlarge the restriction retained by the first proviso. A time-barred jurisdictional notice invalidates the consequential reassessment. Medical incapacity of the person handling an assessee's legal affairs may constitute sufficient cause for condoning filing delay. Case-Laws Income Tax Wed, 07 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801394