Income tax reassessment notice limitation after old Section 148 deemed Section 148A(b); Section 149/TOLA extension upheld, writ dismissed

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....The dominant issue was whether reassessment initiation under the post-01.04.2021 regime was barred by limitation where an earlier notice issued on 30.06.2021 under the erstwhile Section 148 was deemed to be under Section 148A(b). Applying the legal fiction in Ashish Agarwal and the clarification in Rajeev Bansal, the court held that limitation had to be tested by the surviving time under Section 149 read with TOLA, and that a fresh Section 148 notice under the new regime could be issued only if limitation under the old regime had not already expired. Since TOLA extended the old-regime six-year period up to 30.06.2021 and the escaped income exceeded Rs. 50 lakh, the 29.07.2022 notice was within time and had valid Section 151 approval; the writ was dismissed. - HC....