Limitation for reassessment notices under the new regime defeats a belated reopening once the statutory period expires.

A reassessment notice under the Income-tax Act was found unsustainable because it was issued after the applicable limitation period had expired for assessment year 2017-18. The court noted that the relevant six-year period ended on 31.03.2024, while the notice was issued on 28.02.2025, making the reopening time-barred. As the principal notice under Section 148 was barred by limitation, the connected orders under Sections 148A(d) and 148A(b) also could not survive and were set aside, with consequential relief to the assessee.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for the assessment year 2017-18 was barred by limitation in view of the time limits applicable to reassessment proceedings.

Analysis: The relevant six-year period from the end of assessment year 2017-18 expired on 31.03.2024. The impugned notice was issued on 28.02.2025, after the expiry of that period. In such circumstances, the notice could not be sustained as the reopening power was time-barred. The order under Section 148A(d) and the notice under Section 148A(b) also fell with the impugned notice.

Conclusion: The notice under Section 148 was barred by limitation and was set aside, with consequential relief to the assessee.

Ratio Decidendi: A reassessment notice under the new regime cannot be sustained once the applicable limitation period has expired for the relevant assessment year.

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