Reassessment limitation under substituted reopening regime: section 148 notice quashed as time-barred after TOLA extension expired.

Reassessment notices under section 148 were held to be time-barred because they were issued after the extended outer limitation period under the substituted reassessment regime and the TOLA relaxation. Applying the Supreme Court's guidance on the interaction between the amended reassessment provisions and the relaxation framework in Rajeev Bansal, the Tribunal found that the surviving time to issue notice had already expired. As a result, the notices could not confer jurisdiction to reopen the assessments and were quashed.

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Issues: Whether the reassessment notice issued under section 148 for the assessment years in question was barred by limitation in view of the substituted reassessment regime, the relaxation under TOLA, and the principles laid down by the Supreme Court in Rajeev Bansal.

Analysis: The reassessment notices were issued after the extended outer limit available under the applicable limitation framework. The Tribunal applied the Supreme Court's exposition on the interaction between the substituted provisions governing reassessment and the relaxation statute, and held that the surviving period for issuing notice had already expired. On those facts, the notice issued under section 148 was beyond limitation and could not sustain jurisdiction to reopen the assessments.

Conclusion: The reassessment notice was invalid and was quashed as time-barred, with the result that the revenue's appeals failed.

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