Limitation barred reassessment notice and 148A(d) order for Assessment Year 2014-15, leading to quashing of reopening.

Reassessment proceedings for Assessment Year 2014-15 were held unsustainable because the notice under section 148 and the order under section 148A(d) were issued beyond the permissible limitation period. Applying the same limitation principle noted in the earlier Keenara Industries matter for the same assessment year, the High Court quashed and set aside the reopening action as time-barred.

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Issues: Whether the notice issued under section 148 of the Income-tax Act, 1961 and the order passed under section 148A(d) of the Income-tax Act, 1961 for Assessment Year 2014-15 were liable to be quashed on the ground of limitation.

Analysis: The petition challenged the reassessment proceedings initiated for Assessment Year 2014-15. The writ was heard in the backdrop of the Court's earlier decision in Keenara Industries Private Limited, where similar reopening proceedings for the same assessment year were held to be hit by limitation.

Conclusion: The impugned notice under section 148 and the order under section 148A(d) were quashed and set aside as barred by limitation.

Ratio Decidendi: Reassessment proceedings initiated beyond the permissible period of limitation are unsustainable and liable to be set aside.

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