Reassessment limitation and jurisdiction challenge led to interim stay of further proceedings pending writ adjudication.

Reassessment proceedings for assessment year 2013-14 were challenged as time-barred and without jurisdiction, with the notice under Section 148 and the order under Section 148A(d) said to have been issued beyond the permissible period under Section 149(1)(b) of the Income-tax Act, 1961. The Court found a prima facie jurisdictional issue because the initiation appeared to be beyond six years and required full hearing on affidavits. Pending that adjudication, interim protection was granted and further proceedings on the impugned order were stayed until disposal of the writ petition.

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Issues: Whether the reassessment notice and the order under Section 148A(d) of the Income-tax Act, 1961 for assessment year 2013-14 were liable to be interfered with on the ground of lack of jurisdiction and limitation, and whether interim protection was warranted pending adjudication.

Analysis: The writ petition challenged the reassessment initiation on the ground that the notice under Section 148 and the consequential order under Section 148A(d) were issued beyond the permissible period, with reference to Section 149(1)(b) of the Income-tax Act, 1961. The Court noted that the initiation of reassessment proceedings was prima facie beyond six years and that the petitioner had raised a substantial jurisdictional issue requiring affidavits and final hearing. On that basis, the Court found a prima facie case for interim protection.

Outcome: The respondents were directed to file affidavits and, in the meantime, further proceedings on the impugned order were stayed till disposal of the writ petition.

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