Time-barred section 148 notice invalidates reassessment where the statutory limitation had already expired before issuance.

A section 148 notice for assessment year 2015-16 was challenged as time-barred because the applicable outer limitation had expired before the notice was issued on 23.07.2022. Applying the Supreme Court's limitation framework, the relevant deadline was 31.03.2022, so the later notice was beyond limitation and could not sustain a reassessment. The reassessment framed under section 147 on the basis of that notice was therefore quashed.

---

---

Issues: Whether the notice issued under section 148 for assessment year 2015-16 was barred by limitation and, if so, whether the reassessment order based on that notice could survive.

Analysis: The notice under section 148 issued on 23.07.2022 was treated as the foundation of the reassessment. Applying the Supreme Court's limitation framework, the relevant outer limit for issuance had already expired on 31.03.2022 for the assessment year in question. The later notice was therefore beyond limitation, and the reassessment framed on its basis could not stand.

Conclusion: The notice under section 148 was held to be time-barred and was quashed. The reassessment order under section 147 was also quashed, with the result that the assessee succeeded.

---