Reassessment limitation renders post-expiry notices invalid, while missing scrutiny notice or improper approval defeats jurisdiction.
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....Reassessment notices for AY 2015-16 issued on or after 1 April 2021 were required to be dropped because the extended period did not preserve the power to issue fresh notices after limitation expired. Reassessment is also without jurisdiction where a return filed in response to a reassessment notice before completion is treated as non-existent solely because it was belated and no notice under section 143(2) is issued. For reopening beyond three years, prior approval from the higher specified authority is mandatory; TOLA's time extension does not alter the statutory hierarchy, making approval by the Principal Commissioner insufficient.....
TaxTMI