Reassessment limitation under Section 149 barred a Section 148 notice issued after the six-year period expired.

A notice under Section 148 for assessment year 2016-17 was held to be time-barred because the six-year limitation period under Section 149(1)(b) expired on 31.03.2023, while the notice was issued after that date. The limitation framework for reassessment could not revive a proceeding once the statutory period had lapsed, so the impugned notice could not be sustained and was set aside.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for assessment year 2016-17 was barred by limitation in view of the expiry of the six-year period under Section 149(1)(b) of the Act.

Analysis: The relevant six-year period from the end of assessment year 2016-17 expired on 31.03.2023. The notice under Section 148 was issued after that date. In light of the governing limitation framework and the principle that the reassessment regime could not revive a time-barred proceeding for the relevant assessment year, the impugned notice could not be sustained.

Conclusion: The notice under Section 148 was barred by limitation and was liable to be set aside.

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