Limitation for reassessment notices bars revival of an expired six-year period for pre-2021 assessment years.

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....A notice under section 148 issued on 07.04.2022 for A.Y. 2015-16 was treated as time-barred because the first proviso to section 149(1) preserves the limitation applicable to pre-01.04.2021 assessment years. The six-year period under the unamended regime had expired on 31.03.2022, so the amended law could not revive a notice that was already barred. On that basis, the reassessment order founded on the invalid notice was also quashed, and the remaining grounds were left open.....