KLM Steel Pipe Reopening Time Barred

The Tribunal delivers a precise application of limitation jurisprudence post the transition to the new reassessment regime. It holds that once the “clock” of limitation resumes after exclusions mandated by the Supreme Court, the Revenue must act strictly within the residual period.

Any delay, even if marginal, invalidates jurisdiction itself. The ruling underscores that procedural compliance under Section 148A cannot override statutory limitation under Section 149. By quashing both reassessment and consequential penalty, the Tribunal reinforces that jurisdictional defects are fatal and incurable.