Limitation for reassessment notices under the new regime was exceeded, rendering the section 148 notice time-barred.

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....Reassessment notices issued under the new regime were held time-barred because, for notices originally issued between 01/04/2021 and 30/06/2021, only the surviving time available up to 30/06/2021 could be used after excluding the stayed period and the two weeks allowed for response. Applying the Supreme Court rulings in Rajeev Bansal and Ashish Agarwal, the Tribunal held that the fresh notice had to be issued within the remaining limitation under section 149. In this case, the notice issued on 25/07/2022 exceeded that limit, so the reassessment proceedings and assessment orders were quashed, with other grounds left open.....