Reassessment limitation under section 149 bars a section 148 notice beyond three years when escaped income is below the threshold.

Under the reassessment regime, a notice under section 148 issued beyond three years is barred unless the escaped income represented in the prescribed form is fifty lakh rupees or more. The earlier notice under the old regime was treated as a show-cause notice under section 148A, but the governing limitation under section 149 still controlled the fresh initiation. On the admitted facts, the escaped income was below the statutory threshold, so the notice dated 30.07.2022 was time-barred and could not survive. The reassessment proceedings were therefore quashed, while the remaining challenge was left open.

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Issues: Whether the notice issued under section 148 was invalid as time-barred where the escaped income was below fifty lakh rupees.

Analysis: The notice was issued under the new reassessment framework after the earlier notice under the old regime was treated as a show-cause notice under section 148A. The governing time-limit under section 149 permits notice beyond three years only where the escaped income represented in the prescribed form is fifty lakh rupees or more. On the admitted facts, the escaped income in the assessee's case was less than fifty lakh rupees. The statutory limit therefore barred initiation of reassessment beyond three years, and the notice issued on 30.07.2022 could not survive.

Conclusion: The notice under section 148 dated 30.07.2022 was invalid and the reassessment proceedings were quashed. The assessee succeeded on the limitation issue, and the remaining challenge was left open.

Ratio Decidendi: Under the reassessment regime, a notice under section 148 issued after three years is invalid unless the escaped income represented in the prescribed form is fifty lakh rupees or more.

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