Reassessment limitation barred renewal of proceedings where the Section 148 notice was issued after expiry of the statutory period.

Reassessment proceedings for assessment year 2015-16 were found to be barred by limitation because the notice under Section 148 was issued on 28.07.2022 after the limitation period expired on 31.03.2022. Since reassessment had been initiated only after expiry of the statutory time limit, the proceedings could not be sustained and the notices under Sections 148A(d) and 148 were liable to be quashed.

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Issues: Whether the reassessment proceedings for assessment year 2015-16 were barred by limitation and whether the notices issued under Sections 148A(d) and 148 of the Income-tax Act, 1961 were liable to be quashed on that ground.

Analysis: The notice under Section 148 was issued on 28.07.2022 for assessment year 2015-16. The limitation for initiating reassessment for that year had expired on 31.03.2022. Since the reassessment was commenced after expiry of the limitation period, the proceedings could not be sustained.

Conclusion: The reassessment was time-barred and the impugned notices were liable to be quashed.

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