Limitation period in tax reassessment: amended time limits prevent retrospective validation of reassessment notices under the new regime.
The document focuses on the amended reassessment regime introduced by the Finance Act 2021, highlighting the shortened limitation periods and the mandatory pre-notice procedure requiring inquiry and opportunity to be heard. It rejects administrative attempts to render earlier notices compliant with amended law via retrospective treatment, finds the 'travel back in time' theory legally impermissible, and stresses that limitation periods, pandemic-related extensions, and procedural safeguards determine the validity of reopening assessments.