Navigating TOLA and the Rajiv Bansal Ruling: Implications for AY 2013-14 to AY 2017-18 for Reassessment Notices

• Under what circumstances would notices issued for AYs 2013-14 and 2014-15 on 30.06.2021 be deemed to be invalid? Would notices issued beyond the statutory period be treated as time-barred as explained in the case of Rajeev Bansal?

Impact of TOLA on Sanction Timelines

• Does TOLA extend the time limit for the granting of sanction by the authority under Section 151?

Three-Stage Validation Process for Reassessment Notices

• What is the three-stage process to verify the validity of reassessment notices?

Applicability of TOLA for High-Value Notices

• Should notices issued for AY 2015-16 between 01.04.2021 and 30.06.2021, where income escapement exceeds Rs. 50 lakhs, be examined independently of TOLA?

Validity of Notices for AY 2016-17 and 2017-18 with Income Below Rs. 50 Lakhs

• Whether a notice issued between 01.04.2021 and 30.06.2021 for AYs 2016-17 and 2017-18, with an income escapement below Rs. 50 lakhs, valid?

Verification of Surviving Period for High-Income Notices

• Whether verification of the surviving period necessary for notices issued between 01.04.2021 and 30.06.2021 where income escapement exceeds Rs. 50 lakhs for AYs 2016-17 and 2017-18?

Validity of Sanctions under Section 151(i)

• Whether sanction obtained under Section 151(i) for AYs 2016-17 or 2017-18, related to notice issued between July and September 2022, is valid?