Reassessment notice beyond four years required scrutiny against original assessment and section 80IA claim, with interim protection granted.

A reassessment notice under section 148 for assessment year 2014-15, issued beyond four years, was required to be examined against the original assessment under section 143(3) and the taxpayer's section 80IA(4) claim. Interim protection was granted pending further consideration, and the respondents were directed not to pass the final order without leave of the Court until the matter was taken up again.

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Issues: Whether the reassessment notice under section 148 of the Income-tax Act, 1961 for assessment year 2014-15, issued beyond four years, was liable to be examined in light of the original assessment under section 143(3) and the claim under section 80IA(4), and whether interim protection was warranted pending further consideration.

Outcome: Notice issued returnable on 6 May 2021, and the respondents were directed not to pass the final order without leave of the Court in the meantime.

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