Reassessment limitation under Section 148: notice issued after expiry of the prescribed period was set aside.

A notice under Section 148 for assessment year 2017-18 was held barred by limitation because the six-year period from the end of the assessment year expired on 31.03.2024, and the notice was issued thereafter. Applying the reassessment limitation scheme, the court held that a notice issued after expiry of the prescribed period could not be sustained and set it aside.

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Issues: Whether the notice issued 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 period of six years from the end of assessment year 2017-18 expired on 31.03.2024. The impugned notice was issued thereafter. In the light of the limitation scheme governing reassessment, the notice could not be sustained once the prescribed period had expired.

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

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