Limitation for reopening proceedings under section 148A(d) expired, making the consequential reassessment unsustainable.

Reassessment proceedings under section 148A(d) were examined against the limitation framework in section 149 and the time available after the Supreme Court's directions on reopening. The order under section 148A(d) was passed after the surviving statutory period had expired, so the section 148A proceedings were time-barred. As the foundational notice and reassessment steps were beyond the permitted window, the consequential reassessment could not be sustained in law and was quashed.

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Issues: Whether the order under section 148A(d) and the consequential reassessment were barred by limitation and liable to be quashed.

Analysis: The reassessment timeline was examined against the limitation framework under section 149 and the time available after the Supreme Court's directions in the reopening regime. The order under section 148A(d) was passed after the surviving time limit had expired. Since the statutory window for completing the section 148A proceedings had already run out, the consequential reassessment could not be sustained in law.

Conclusion: The order under section 148A(d) and the consequential reassessment were barred by limitation and were quashed.

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