Reassessment limitation bars Section 148 notice issued after expiry of the prescribed period; notice set aside.

A notice under Section 148 of the Income-tax Act for assessment year 2017-18 was held time-barred because the six-year limitation period expired on 31.03.2024 and the notice was issued thereafter. Applying the governing limitation provisions and the Supreme Court's exposition on the prospective operation of the reassessment regime, the court held that the notice could not survive once the prescribed period had lapsed. The notice was accordingly set aside.

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Issues: Whether the notice under Section 148 of the Income-tax Act, 1961 for assessment year 2017-18 was barred by limitation and liable to be set aside.

Analysis: The six-year period relevant to the assessment year expired on 31.03.2024. The impugned notice was issued thereafter. In light of the governing limitation provisions and the Supreme Court's exposition on the prospective operation of the reassessment regime, the notice could not survive once the prescribed period had expired.

Conclusion: The notice under Section 148 was time-barred and was set aside.

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