Limitation bars reassessment notice under Section 148, leading to quashing of the consequential Section 148A(d) order.

Reassessment action was held unsustainable where the Section 148 notice and the consequential Section 148A(d) order were barred by limitation. Applying its earlier reasoning in similar matters for the relevant assessment year, the Gujarat HC found that the impugned reassessment proceedings could not be continued. The notice under Section 148 and the order under Section 148A(d) were quashed, and the writ petition was allowed.

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Issues: Whether the reassessment notice under Section 148 of the Income-tax Act, 1961, along with the order under Section 148A(d), was liable to be quashed on the ground of limitation.

Analysis: The petition was decided in the light of the earlier decision of the same Court in similar matters concerning notices issued for the relevant assessment year. Applying that reasoning, the Court found that the impugned reassessment action could not be sustained.

Conclusion: The challenge to the notice under Section 148 and the order under Section 148A(d) succeeded, and both were quashed.

Final Conclusion: The reassessment proceedings based on the impugned notice did not survive and the writ petition was allowed.

Ratio Decidendi: Where reassessment action is barred by limitation, the notice under Section 148 and the consequential order under Section 148A(d) cannot be sustained.

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