Time-barred reassessment notice under section 148 invalidates all consequential proceedings and orders.

A reassessment notice issued under section 148 was treated as time-barred because it fell under the earlier limitation regime applicable to the assessment year, and the jurisdictional High Court's binding view was followed. The revenue's reliance on the COVID-19 extension was rejected in light of the controlling precedents. As the notice was beyond the permissible limitation period, the consequential reassessment proceedings and orders were quashed in favour of the assessee.

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Issues: Whether the notice issued under section 148 of the Income-tax Act, 1961 for the relevant assessment year was time-barred and, if so, whether the consequential proceedings and orders were liable to be quashed.

Analysis: The appeal was decided by following the binding view of the jurisdictional High Court on the same issue. The notice under section 148 was issued for an assessment year governed by the earlier limitation regime, and the Court accepted that the notice was beyond time. The revenue's reliance on the COVID-19 extension was not accepted in view of the controlling precedents relied upon.

Conclusion: The notice under section 148 was held to be time-barred, and the consequential proceedings and orders were quashed in favour of the assessee.

Ratio Decidendi: A reassessment notice issued beyond the permissible limitation period is invalid and all proceedings founded on such notice must be quashed.

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