Reassessment notice barred by limitation after expiry of the statutory six-year period, invalidating consequential proceedings.

Reassessment under the Income-tax Act was found time-barred where the notice under Section 148 for assessment year 2015-16 was issued after expiry of the six-year period under Section 149(1)(b). As the limitation period had ended on 31.03.2022, the reassessment notice could not be sustained, and the consequential notice and order under Sections 148A(b) and 148A(d) were quashed. The challenge was accepted on limitation grounds, with no survival of the later reassessment proceedings.

---

---

Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for assessment year 2015-16 was barred by limitation in view of the expiry of the period prescribed under Section 149(1)(b), and whether the consequential notice and order under Sections 148A(b) and 148A(d) could survive.

Analysis: The period of six years from the end of assessment year 2015-16 expired on 31.03.2022. The impugned notice was issued thereafter. On the applicable limitation framework, a notice under the reassessment provisions could not be sustained once the relevant time limit had expired. The challenge was accepted by the respondent as well.

Conclusion: The reassessment notice was barred by limitation and could not survive; the consequential notice and order also stood quashed.

---