Reassessment notices were invalid for limitation and non-faceless initiation under the amended reassessment regime.

Reassessment for assessment year 2017-18 was held time-barred because the notice under Section 148 dated 16.04.2024 had to be tested against the limitation law in force on that date and was beyond both the pre-amendment and amended time limits, with no statutory exception shown. Reassessment initiated after 01.04.2021 by the jurisdictional Assessing Officer, rather than through the faceless mechanism, was also held impermissible under the amended framework and binding precedent. The reassessment action therefore failed on limitation and procedure, and the impugned notices and order were not sustained.

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Issues: (i) Whether reassessment proceedings for assessment year 2017-18 were barred by limitation under Section 149(1) of the Income-tax Act, 1961 when the notice under Section 148 was issued on 16.04.2024. (ii) Whether reassessment proceedings initiated by the jurisdictional Assessing Officer after 01.04.2021, instead of through the faceless mechanism, were valid.

Issue (i): Whether reassessment proceedings for assessment year 2017-18 were barred by limitation under Section 149(1) of the Income-tax Act, 1961 when the notice under Section 148 was issued on 16.04.2024.

Analysis: The relevant notice had to be tested with reference to the law in force on the date of issuance. For an assessment year beginning before 01.04.2021, the proviso to the amended limitation regime required the Court to examine whether the notice was already barred under the unamended time limits. On the dates relevant to assessment year 2017-18, the outer limit under the earlier regime had expired, and the notice issued on 16.04.2024 was beyond both the pre-amendment and the post-amendment permissible period. No material showed that the case fell within any statutory exception.

Conclusion: The reassessment notice and consequential proceedings were barred by limitation and invalid in favour of the assessee.

Issue (ii): Whether reassessment proceedings initiated by the jurisdictional Assessing Officer after 01.04.2021, instead of through the faceless mechanism, were valid.

Analysis: The post-01.04.2021 reassessment framework required proceedings to be undertaken in the faceless manner. The Court treated the issue as already settled by earlier binding precedent and applied that position to hold that initiation by the jurisdictional Assessing Officer was impermissible. The procedural course adopted therefore vitiated the reassessment action.

Conclusion: The proceedings initiated by the jurisdictional Assessing Officer were invalid and the point was decided in favour of the assessee.

Final Conclusion: The reassessment action failed on both limitation and procedure, and the impugned notices and order could not be sustained.

Ratio Decidendi: A reassessment notice must satisfy the limitation regime applicable on the date of issuance, and post-01.04.2021 reassessment proceedings must conform to the faceless procedure mandated by the amended law.

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