Reassessment limitation under Section 148 barred the reopening, and the consequential assessment order could not survive.

Reassessment under Section 148 for AY 2016-17 was held time-barred because the notice was issued after the six-year limitation period from the end of the relevant assessment year, and after expiry of the period preserved by the proviso to Section 149(1)(b). The court applied the governing limitation framework and held that the reopening could not be sustained once that period had expired on 31.03.2023. As the reassessment notice was invalid, the order under Section 148A(d) and the consequential assessment order based on that reopening were also set aside.

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Issues: Whether the reassessment notice issued under Section 148 of the Income-tax Act, 1961 for Assessment Year 2016-17 was barred by limitation and, consequently, whether the notice, the preceding order under Section 148A(d), and the assessment order were liable to be set aside.

Analysis: The notice was issued for Assessment Year 2016-17 after the expiry of six years from the end of the relevant assessment year. The governing limitation under the reassessment framework, as explained in the cited authority, required the Revenue to act within the period preserved by the proviso to Section 149(1)(b) of the Income-tax Act, 1961. Since that period had already expired on 31.03.2023, the impugned notice could not be sustained. The consequent assessment order, based on the invalid reopening, also could not stand.

Conclusion: The reassessment notice was barred by limitation and was rightly set aside along with the consequential assessment order.

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