Reassessment time bar under the new regime invalidated a Section 148 notice for Assessment Year 2015-2016.

Reassessment action under the new regime could not be sustained for Assessment Year 2015-2016 where the notice under Section 148 was issued on or after 1 April 2021 and fell outside the period treated as permissible under the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Relying on the Revenue's concession recorded in Rajeev Bansal, the Delhi HC treated the impugned Section 148A(d) action and consequential Section 148 notice as time-barred, and the writ petition was allowed.

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Issues: Whether the reassessment action initiated under Section 148A(d) and the consequential notice under Section 148 of the Income-tax Act, 1961 for Assessment Year 2015-2016 could be sustained in light of the limitation position clarified in relation to the new reassessment regime and the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020.

Analysis: The petition challenged a reassessment notice issued on 23 July 2022 for Assessment Year 2015-2016. The determining factor was the concession recorded on behalf of the Revenue in Rajeev Bansal, where it was ed that for Assessment Year 2015-2016, notices issued on or after 1 April 2021 were liable to be dropped as they would not fall within the period prescribed under the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. On that basis, the impugned reassessment action was outside the permissible time period.

Conclusion: The reassessment proceedings could not be sustained and the writ petition was allowed.

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