Limitation for reassessment notice under the Income-tax Act expired, making the Section 148 notice invalid and unsustainable.

A notice under Section 148 for assessment year 2015-16 was held barred by limitation because it was issued after the expiry of six years from the end of the relevant assessment year. The recorded facts showed that the limitation period ended on 31.03.2022, and the notice was issued thereafter. The notice was therefore invalid and could not be sustained, and it was set aside in favour of the petitioner.

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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 Section 149(1)(b) of the Act.

Analysis: The notice under Section 148 was issued after the expiry of six years from the end of the relevant assessment year. On the facts recorded, the limitation period had ended on 31.03.2022, whereas the impugned notice was issued thereafter. The notice was therefore hit by limitation and could not be sustained.

Conclusion: The impugned notice under Section 148 was invalid and was set aside in favour of the petitioner.

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