Limitation on reassessment reopening bars notice and 148A(d) order where the assessment year fell outside the permissible period.

Reassessment notice under Section 148 and the accompanying order under Section 148A(d) were held unsustainable where the reopening for assessment year 2013-14 was found barred by limitation. Applying its earlier ruling on the same limitation issue, the HC concluded that the jurisdictional precondition for reopening was not met and quashed both the notice and the Section 148A(d) order.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 and the order passed under Section 148A(d) of the Income-tax Act, 1961 for reopening the assessment for assessment year 2013-14 were barred by limitation and liable to be quashed.

Analysis: The petition was filed under Article 226 of the Constitution of India challenging the reassessment notice and the order passed under Section 148A(d). The assessment year in question was 2013-14, and the Court applied the limitation principle in the light of its earlier decision on the same issue. On that basis, the reopening was held to be unsustainable.

Conclusion: The notice under Section 148 of the Income-tax Act, 1961 and the order under Section 148A(d) of the Income-tax Act, 1961 were quashed and set aside.

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