Reassessment notice limitation barred the Section 148 notice for Assessment Year 2015-16, as later relaxations could not revive it.

A reassessment notice under Section 148 issued for Assessment Year 2015-16 on 23.07.2022 was held time-barred because it was issued after the outer limitation period applicable to that year. The extended regime and relaxation framework did not save the notice, as later procedural relaxations cannot revive a notice already beyond limitation unless the statute expressly permits it. The challenge to the validity of the notice therefore succeeded on limitation, and the notice was treated as invalid.

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Issues: Whether the reassessment notice issued under Section 148 of the Income-tax Act, 1961 for Assessment Year 2015-16 on 23.07.2022 was barred by limitation.

Analysis: The notice was issued after the outer time limit applicable to the relevant assessment year. The legal position applied was that the extended regime and the relaxation framework did not save a notice issued beyond the limitation period for Assessment Year 2015-16. The challenge to the validity of the notice therefore succeeded on the ground of limitation.

Conclusion: The reassessment notice dated 23.07.2022 was time-barred and the issue was decided in favour of the assessee.

Ratio Decidendi: A reassessment notice issued for an assessment year beyond the prescribed limitation period is invalid, and later procedural relaxations do not revive a time-barred notice unless the statute expressly so provides.

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