Validity of Reassessment Notices Post-Ashish Agarwal and TOLA: Limitation and Sanction u/ss 149 and 151

Reassessment notices: surviving-time computation under COVID-era relief and new limitation rules renders late notices time-barred.

The court held that in transitional reassessment cases the appropriate sanctioning authority is determined by when the original three-year expiry fell within the COVID-era relief window, so approval by the ordinarily specified authority for within-three-year cases suffices; limitation is governed by a two-step surviving-time computation measured from the original notice as of the relief-window terminal date, excluding stayed periods and the time allowed to reply, and any later notice issued beyond that surviving time is time-barred under the substituted limitation regime read with the time-relief statute and the legal-fiction continuity.