Reassessment limitation and jurisdiction: time-barred notice rendered the resulting income-tax proceedings invalid.

A reassessment notice issued beyond the last permissible date under the reassessment timeline, read with the relaxation under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, was held time-barred. As reassessment provisions operate as jurisdictional machinery, a notice issued after the surviving limitation period is invalid and the resulting assessment proceedings cannot stand. The assumption of jurisdiction therefore failed, and the merits of the additions were not examined.

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Issues: Whether the reassessment notice issued under section 148 of the Income-tax Act, 1961 was barred by limitation and, if so, whether the resulting assessment proceedings were without jurisdiction.

Analysis: The notice under section 148 was found to have been issued after the last permissible date determined from the applicable reassessment timeline read with the relaxation provided under section 3(1) of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The reassessment provisions were treated as jurisdictional machinery provisions, and a notice issued beyond the surviving period was held to be invalid. Since the assumption of jurisdiction itself failed, the merits of the additions were not examined.

Conclusion: The reassessment notice was time-barred, the consequential assessment proceedings were not legally sustainable, and the assessee succeeded on the jurisdictional issue.

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