Reassessment limitation under sections 148 and 148A rendered the notice invalid after the permissible period expired.

Reassessment under sections 148, 148A, 149 and 151 of the Income-tax Act was found time-barred because the extended period for issuing notice had already run and only the residual time after the earlier notice and section 148A proceedings remained available. On the facts recorded, the last valid date for issue of notice under section 148 expired on 23.07.2022, but the notice was issued on 27.07.2022. The notice was therefore without jurisdiction, and the assessment founded on it could not survive; the limitation and jurisdictional objections were accepted in favour of the assessee.

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Issues: Whether the reassessment notice issued under section 148 and the consequent assessment for assessment year 2013-14 were barred by limitation and without jurisdiction.

Analysis: The period for issuance of notice had already stood extended up to 30.06.2021, and only the residual time available after the earlier notice and the proceedings under section 148A had to be accounted for. On the facts recorded, the last date for issuing a valid notice under section 148 expired on 23.07.2022, whereas the notice was issued on 27.07.2022. The Tribunal applied the limitation framework governing reassessment under sections 148, 148A, 149 and 151 of the Income-tax Act, 1961, and held that the notice was issued after the permissible period.

Conclusion: The reassessment notice was time-barred and invalid, and the assessment founded on it was unsustainable; the grounds challenging jurisdiction and limitation were accepted in favour of the assessee.

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