Reassessment limitation under the amended regime barred a Section 148 notice for Assessment Year 2014-15.

A reassessment notice for Assessment Year 2014-15 was held unsustainable because, under the amended reassessment regime applicable from 1 April 2021, reopening had to satisfy the limitation under Section 149 or the search-based framework under Sections 153A and 153C. On the stated facts, the year fell beyond the ten-year block period, and the search-related computation did not extend the permissible period for that assessment year. The notice under Section 148 was therefore time-barred and liable to be quashed.

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Issues: Whether the notice issued under Section 148 for Assessment Year 2014-15 was barred by limitation under the amended reassessment regime applicable from 01 April 2021, read with the limitation structure under Section 149 and the search-related provisions under Sections 153A and 153C.

Analysis: The notice dated 06 February 2024 was subject to the amended regime of reassessment. For an assessment year preceding 01 April 2021, reopening could be sustained only if it satisfied the applicable time limits under Section 149(1)(b) or the special regime under Sections 153A and 153C. On the facts noted, the relevant reckoning placed Assessment Year 2014-15 beyond the ten-year block period, and the search-related computation did not extend the permissible period so as to validate reopening for that year.

Conclusion: The notice under Section 148 for Assessment Year 2014-15 was unsustainable and liable to be quashed.

Ratio Decidendi: A reassessment notice for a pre-01 April 2021 assessment year cannot be sustained unless it falls within the statutorily permitted limitation under the amended Section 149 regime or the applicable search-based provisions, and a year lying beyond the ten-year block is time-barred.

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