Limitation barred reassessment proceedings under Section 148; delayed notice and consequential actions were set aside.

Reassessment notice under Section 148 and the consequential proceedings under Sections 148A(b) and 148A(d) were held time-barred, as they were issued beyond the prescribed limitation period. The court treated the dispute as covered by binding precedent on delayed reassessment action and found such proceedings unsustainable when initiated after expiry of the permissible time limit. The impugned notice and all proceedings pursuant to it were therefore set aside in favour of the assessee.

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Issues: Whether the notice under Section 148 of the Income-tax Act, 1961 and the consequential proceedings under Section 148A(b) and Section 148A(d) were barred by limitation and liable to be set aside.

Analysis: The petition challenged the reassessment notice and the subsequent order on the ground that they were issued beyond the prescribed period. The controversy was treated as covered by the cited binding decision, under which similar proceedings were held unsustainable when initiated beyond the permissible period.

Conclusion: The impugned notice and all proceedings initiated pursuant to it were set aside, in favour of the assessee.

Ratio Decidendi: Reassessment proceedings initiated beyond the prescribed limitation period are unsustainable and liable to be quashed.

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