Reassessment notice limitation challenge sent back for decision in accordance with law and relevant precedent.

A reassessment notice issued under section 148 after expiry of the limitation period was challenged, with the court directing that the matter be decided in accordance with law. The Assessing Officer was required to consider the precedent relied upon and the respondents' stated position while disposing of the proceedings. The petition was therefore disposed of with directions, rather than on a substantive adjudication of the reassessment issue.

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Issues: Whether the reassessment notice issued under Section 148 of the Income-tax Act after expiry of the limitation period called for interference, and whether the Assessing Officer should decide the proceedings by taking into account the precedent relied upon and the respondents' stated position.

Outcome: The petition was disposed of with directions to the Assessing Officer to decide the proceedings in accordance with law, keeping in view the precedent relied upon and the respondents' submissions.

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