Time-barred notices: TOLA and amended reassessment rules reshape reopening scope and create interpretational uncertainty.
Whether reassessment notices issued after 1 April 2021 are governed by the substituted reassessment regime depends on the interaction between the Finance Act 2021's procedural and temporal reforms, TOLA's time extension notifications, and the proviso protecting notices that had already become time barred under the pre amendment law. Conflicting interpretations hinge on whether TOLA's non obstante clause and extensions override the proviso broadly or only to the extent of the specified extension window, producing uncertainty about applicability to particular assessment years and the operation of the three year and ten year reopening thresholds. (AI Summary)