Reopening Tax Assessments: Issuance Date of Notice Key to Validity Under New Section 148A Rules, Says High Court.

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....Validity of reopening of assessment - period of limitation for issuance of notice u/s 148 - It is not the actual communication of the notice that is relevant. It is the issuance of the notice. - Scope of new regime u/s 148A - Once the notice has been dispatched either electronically or through post on the last date prescribed u/s 149 the proceeding cannot be questioned as time barred. - HC....