Reassessment notice limitation defeated where service occurred after the deadline, making the proceeding unsustainable.

A reassessment notice under Section 148 was held time-barred where it was signed on 31 March 2021 but communicated on 1 April 2021. The Court followed its earlier precedent, affirmed on appeal, and noted that the revenue could not distinguish those decisions on the facts. On that basis, the reassessment initiation and the consequential proceeding were found unsustainable and were quashed with all consequential legal effects.

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Issues: Whether the reassessment notice and consequent proceeding were barred by limitation on the ground that the notice, though signed on 31 March 2021, was communicated on 1 April 2021.

Analysis: The writ petition challenged the notice under Section 148 of the Income-tax Act, 1961 and the consequential order on the ground that the initiation of reassessment was time-barred. The Court noted the reliance placed on the earlier decision of this Court, as affirmed in appeal, and recorded that the revenue was not in a position to distinguish those decisions. Following that precedent and the facts of the case, the Court found the impugned proceeding unsustainable.

Conclusion: The challenge succeeded and the reassessment proceeding was quashed, with all consequential legal effects.

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