Notice issued u/s 148 beyond the limitation period prescribed under erstwhile provisions of section...

Notice issued u/s 148 beyond the limitation period prescribed under erstwhile provisions of section 149(1)(b) is barred by limitation, even after considering the relaxation provided by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The first proviso to section 149 does not enable issuance of notice u/s 148 after April 1, 2021, if it could not have been issued under the erstwhile provisions on the date of impugned notice. The reassessment proceedings are invalid if the notice is issued beyond the extended time limit provided by the relaxation act. .....

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