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of <h1>Reassessment notices under sections 148, 148A(d), 149 and 151 held time-barred despite valid transitional regime sanction</h1> Gujarat High Court considered writ petitions challenging reassessment proceedings for AYs 2013-14, 2014-15, 2016-17 and 2017-18 under sections 148 and 148A(d) in the transitional regime post Finance Act 2021, TOLA, and Supreme Court rulings in Ashish Agarwal and Rajeev Bansal. The Court upheld sanction granted by the Principal Commissioner/Commissioner under section 151(i), holding that the competent authority is determined with reference to the original three-year limitation falling within the TOLA window, and that later notices form a continuum. However, applying the 'surviving time' methodology under section 149 and TOLA as clarified in Rajeev Bansal, the Court held all impugned notices time-barred and quashed the reassessment proceedings.
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