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Issues: Whether the reassessment notice issued under the new regime was barred by limitation in view of the time limits under the Income-tax Act, 1961 read with the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, and whether the sanction requirement under Section 151 was complied with.
Analysis: The notice under Section 148 was issued after the period that survived even after applying the relaxation contemplated by Section 3(1) of the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The binding principles drawn from the Supreme Court decisions on the substituted reassessment provisions made it clear that TOLA could extend only the surviving limitation period and that notices issued beyond that period were liable to be set aside. Since the impugned notice was issued on a date beyond the extended cutoff, the jurisdiction to reopen had not been validly assumed. In view of the quashing of the notice itself, the merits were not examined.
Conclusion: The reassessment notice was time-barred and invalid, and the challenge to reopening succeeded.
Final Conclusion: The reopening could not be sustained, so the Revenue's appeal failed and the assessee's relief was maintained.
Ratio Decidendi: A reassessment notice issued beyond the limitation period surviving after application of TOLA to the substituted reassessment provisions is without jurisdiction and must be set aside.
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