Reassessment limitation under section 153(2) ran from later notice service, while additions were remitted for fresh appellate review.

Reassessment limitation was computed from service of the later section 148 notice, not the earlier service, so assessment orders passed on 28.03.2013 fell within the period under section 153(2). The limitation challenge was rejected. Because the first appellate authority had not examined the merits of the additions, those grounds were remitted for fresh adjudication. The article thus states that the reassessment was within time, while the substantive additions required reconsideration by the appellate authority.

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Issues: Whether the reassessment was barred by limitation in view of the notice under section 148 of the Income-tax Act, 1961 served on 06.04.2011 and whether the merits of the additions required fresh adjudication.

Analysis: The notice first served on 25.03.2011 and a second notice served on 06.04.2011 were both dated 22.03.2011. The time limit for completion of reassessment was held to run from the date of service of the latter notice, and the assessment orders passed on 28.03.2013 were within the permissible period under section 153(2) of the Income-tax Act, 1961. The first issue was therefore decided against the assessee. Since the first appellate authority had not adjudicated the grounds challenging the additions on merits, those issues were sent back for consideration.

Conclusion: The reassessment was held to be within limitation. The challenge to the additions was remitted for fresh decision by the first appellate authority.

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