S. 153: Assessment-Reassessment-Limitation-Order giving effect to the order of the Tribunal-Assessing Officer failed to give effect to the Tribunal’s directions for ten years-Time granted by the Single Judge for refund was to be extended by another eight weeks.[S,143(3), 254(1), Art. 226]

S. 153: Assessment-Reassessment-Limitation-High Court’s order merely laid down timelines for furnishing reasons and disposing of objections; it did not constitute a ‘finding or direction’ under section 153(6)(i)-Applying section 153(2), first proviso, read with the first proviso to Explanation 1 to section 153, reassessment was barred by limitation.[S.147, 148, 153(6)(i), Art. 226]

S. 149 : Reassessment-Time limit for notice-Sanction-Non-resident-Notice under section 148 was issued within three years; sanction under section 151 by PCIT was valid-Decision is pending consideration before Supreme Court, Jurisdictional Assessing Officer was competent to issue notices under sections 148A/148-[S. 10(4)(ii), 10(14), 10(15)(fa), 148, 148A(b), 148A(d), 151, 151A, 26AS, Art. 226,]

S. 149: Reassessment-Time limit for notice-For assessment year 2015-16, all notices issued on or after 1-4-2021 under sections 148 and 148A were liable to be dropped as they did not fall within the period prescribed under TOLA.[S. 147, 148, 148A(b), 148A(d), TOLA, Art. 226]

S. 149: Reassessment-Time limit for notice-Form of an asset had escaped assessment-All notices issued on or after 1-4-2021 would have to be dropped as they would not fall within the period prescribed under TOLA-Notice under section 148 and all consequential orders/notices, including recovery notices thereof, were quashed and set aside.[S. 148, 148A(b), 148A(d), Art.226]

S. 149 : Reassessment-Time limit for notice-First proviso to section 149(1) Acts as a restriction on retrospective application of extended ten-year limitation period-Reassessment notice under section 148 was issued in 2024 for assessment year 2013-14, but under erstwhile provisions (as extended by TOLA) time limit for issuance of such notice had already expired on 30-06-2021, by virtue of first proviso to section 149(1), revenue was barred from issuing notice under section 148 under new regime, notwithstanding ten-year period provided in section 149(1)(b) after its amendment by Finance Act, 2021.[S. 148,149(1)(b), TOLA, Art. 226]

S. 149 : Reassessment-Time limit for notice-Six years for relevant assessment year 2016-17, expired on 31-3-2022-SLP of revenue dismissed on account of delay of 411 days and also on merits. [S. 148, Art. 136]

S. 149: Reassessment-Time limit for notice-Search-Notice was issued beyond the period of six years from the end of the relevant assessment year; said notice was barred by limitation in terms of the first proviso to section 149(1)-SLP dismissed. [S. 132, 148, 148A(b), 148A(d), Art. 136]

S. 149: Reassessment-Time limit for notice-High Court held that where the period of six years from the end of the relevant assessment year 2016-17 expired on 31.03.2023, notice issued thereafter on 31.03.2024 was barred by limitation-SLP of revenue dismissed. [S. 148, Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Constitutional validity-Notice issued to the Attorney General of India-Arguable questions were raised in the petition; operation of the notice dated 30-3-2025 under section 148 was stayed. [S.148, Explanation 2, Clause (c), Art. 14, 226]