Limitation for reassessment notice extended by pandemic exclusion; notice under income-tax law was treated as timely.

A reassessment notice under Section 148 of the Income-tax Act was found to be within limitation because it was issued within the six-year period in Section 149(1)(b), and the limitation period was further extended by the Supreme Court's suo motu exclusion of time during the pandemic. The period from 15.03.2020 to 28.02.2022 was excluded, so the notice was not time-barred. The extension applied to statutory proceedings initiated by the Department as well as proceedings brought by litigants, and the challenge to the notice failed.

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Issues: Whether the reassessment notice issued under Section 148 of the Income-tax Act, 1961 was barred by limitation under Section 149(1)(b), or saved by the extension of limitation ordered during the pandemic.

Analysis: The notice was issued within six years from the end of the relevant assessment year under Section 149(1)(b). Although that period would otherwise have expired on 31.03.2020, the period from 15.03.2020 to 28.02.2022 stood excluded by the Supreme Court's suo motu extension of limitation. The saving of limitation applied to statutory proceedings initiated by the Department as well as proceedings instituted by litigants.

Conclusion: The notice was held to be within limitation and the challenge to it failed.

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