Limitation for reassessment notices governed the dispute, resulting in quashing of the reassessment process and consequential actions.

Reassessment proceedings were treated as barred by limitation under the applicable High Court precedent. The reassessment notice issued under Section 148A(b), the order under Section 148A(d), the notice under Section 148, and consequential actions were quashed. The remaining contentions were not adjudicated because the limitation issue alone disposed of the petition.

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Issues: Whether the reassessment notice, order and consequent notice for the relevant assessment year were sustainable in view of limitation.

Analysis: The limitation issue was agreed to be governed by the applicable precedent of the High Court. The petition was disposed of solely on that issue, without adjudicating the remaining contentions.

Conclusion: The reassessment notice issued under Section 148A(b), the order under Section 148A(d), the notice under Section 148, and consequential actions were quashed as barred by limitation.

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