Limitation bar on reassessment notice under Section 148 led to the reopening being set aside.

The notice under Section 148 for assessment year 2016-17 was held to be barred by limitation because the six-year period under Section 149(1)(b) expired on 31.03.2022, and the notice was issued afterwards. Earlier proceedings under Section 148A(b) and Section 148A(d) did not save the notice from the limitation bar. The reopening could therefore not be sustained, and the impugned notice was set aside.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for assessment year 2016-17 was barred by limitation in view of Section 149(1)(b) and the earlier proceedings under Section 148A(b) and Section 148A(d).

Analysis: The applicable limitation period of six years from the end of the relevant assessment year expired on 31.03.2022 for assessment year 2016-17. The impugned notice was issued thereafter. In these circumstances, the reopening notice could not be sustained, and the impugned notice was hit by limitation.

Conclusion: The notice under Section 148 was barred by limitation and was set aside.

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