S. 151 : Reassessment-Sanction for issue of notice-Jurisdiction-For a notice issued after three years from the end of the assessment year, sanction granted by the PCIT instead of the PCCIT is invalid. [S.148, 148A(b) 148A(d), 151(i), 151(ii), Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Reopening after three years-Approval by PCIT instead of PCCIT-Sanction held invalid. [S. 148, 148A(b), 148A(d), 151(ii), Art. 226]

S. 151: Reassessment-Sanction for issue of notice-For a notice issued after three years, sanction must be granted by the authority specified in section 151(ii); sanction under section 151(i) is invalid. [S. 147, 148, 148A, 151(1), 151(ii), Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3]

S. 149: Reassessment-Time limit for notice-(AY. 2013-14)-Notice issued in July 2022 pursuant to Supreme Court decision in Ashish Agarwal is barred by limitation as the time limit under the unamended Act, including extensions under TOLA, had expired on 31.03.2021. [S. 147, 148, 148A, Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3]

S. 149 : Reassessment-Time limit for notice-Notice for AY 2014-15 issued on 25.07.2022-Time limit under pre-amended law having expired on 31.03.2021-Notice held time-barred and quashed in view of first proviso to substituted Section 149. [S. 148, 148A(b),148A(d), Art. 226]

S. 149 : Reassessment-Time limit for notice-For AY. 2014-15, deadline expired on 31.03.2021-Notice issued on 25.07.2022 is barred by limitation. [S. 148, 148A(b), 148A(d), Art. 226]

S. 149 : Reassessment-Time limit for notice-For AY 2015-16, the six-year limitation period expired on 31.03.2022. Notice under Section 148 issued on 25.07.2022 was barred by limitation per the first proviso to Section 149, rendering consequential proceedings void. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 149 : Reassessment-Time limit for notice-For AY. 2013-14, limitation under erstwhile provisions expired on 31-03-2020-Reopening notice issued after 31-03-2021 held to be time-barred. [S. 148, Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3, Art. 226]

S. 149 : Reassessment-Time limit for notice-(AY. 2013-14)-Notice issued in July 2022 pursuant to Supreme Court decision in Ashish Agarwal is barred by limitation as the time limit under the unamended Act, including extensions under TOLA, had expired on 31.03.2021. [S. 147, 148, 148A, Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3]

S. 149 : Reassessment-Time limit for notice-Notice for AY 2014-15 issued on 25.07.2022-Time limit under pre-amended law having expired on 31.03.2021-Notice held time-barred and quashed in view of first proviso to substituted Section 149. [S. 148, 148A(b),148A(d), Art. 226]