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    Reconciling Procedural Timelines with Limitation Periods in Income Tax Reassessments
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    Case LawsIncome Tax
    Reconciling Procedural Timelines with Limitation Periods in Income Tax Reassessments
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    Limitation periods: reassessment procedures must be completed within the overarching statutory period, else notices are time-barred.
    The decision construes the interaction between procedural timelines for reassessment and the overarching limitation period, treating the mandatory pre-notice procedure requiring provision of material and an opportunity to respond as part of the reassessment process that must be completed within the ultimate limitation period; if the authority does not complete both the procedural order and issue the reassessment notice within the residual time remaining after statutory exclusions and extensions, the notice is time-barred.

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