Limitation under section 149 barred reopening where the section 148 notice was issued after the prescribed six-year period.

A notice under section 148 for assessment year 2015-16 was held to be time-barred because the six-year limitation under section 149(1)(b) expired on 31 March 2022, while the notice was issued on 29 April 2022. On that basis, the reopening of assessment could not be sustained and was quashed in favour of the assessee.

---

---

Issues: Whether the notice under section 148 issued for assessment year 2015-16 was barred by limitation and, if so, whether the reopening of assessment was liable to be quashed.

Analysis: The relevant assessment year was 2015-16, so the six-year period under section 149(1)(b) expired on 31 March 2022. The notice under section 148 was issued on 29 April 2022, which was beyond the prescribed limitation. On that basis, the reopening could not be sustained.

Conclusion: The notice under section 148 was time-barred and the reopening of assessment was quashed in favour of the assessee.

---