Reassessment limitation bars a Section 148 notice once the relevant assessment-year period has expired, making the notice invalid.

A reassessment notice under Section 148 for AY 2014-15 was issued after the six-year limitation period had expired on 31.03.2021. Applying the limitation framework governing reassessment, the Delhi HC held that a notice issued after expiry of the relevant period cannot be sustained. The notice was therefore time-barred and was set aside in favour of the assessee. The stated principle is that a reassessment notice under the new regime is invalid once the limitation period applicable to the assessment year has already lapsed.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for AY 2014-15 was barred by limitation and liable to be set aside.

Analysis: The period of six years from the end of AY 2014-15 expired on 31.03.2021. The impugned notice was issued thereafter. In view of the limitation framework governing reassessment, the notice could not survive once the relevant period had expired.

Conclusion: The notice under Section 148 was time-barred and was rightly set aside, in favour of the assessee.

Ratio Decidendi: A reassessment notice issued under the new regime cannot be sustained once the limitation period applicable to the relevant assessment year has already expired.

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