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Corporate TaxArticle·1 May 2026

Reassessment Time Barred

By J the App

Executive Summary

In a brief but consequential order, the Supreme Court declined to interfere with the Delhi High Court’s decision quashing reassessment proceedings as time-barred. 

The High Court had applied the Supreme Court’s ruling in Rajeev Bansal to hold that reassessment notices under the new regime cannot revive cases already barred under the old limitation framework. 

By dismissing the SLP, the Supreme Court effectively reinforces the principle that extended timelines under the new regime cannot operate retrospectively to reopen time-barred assessments. While the dismissal is non-speaking, it significantly strengthens taxpayer position in legacy reassessment disputes involving transition provisions.

Tax Domain; Income Tax – Corporate Tax - Reassessment / Limitation / Section 148

Case Details ; Supreme Court of India | 2...

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