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Corporate TaxArticle·10 April 2026

Limitation Bars Reopening

By J the App

Executive Summary

This ruling reinforces a critical limitation principle in reassessment law, the new extended time limits cannot revive dead proceedings.

Where the six-year limitation under the old regime had already expired, reassessment notices issued under the new regime are barred.

The Supreme Court’s dismissal, both on delay and merits, lends finality to this position and strengthens taxpayer protection against retrospective reopening.

Issues for Determination

The core issue was whether reassessment proceedings under Section 148 for AY 2016–17 could be valid...

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