Limitation for reassessment notice under section 148 rendered the notice time-barred and the proceedings void ab initio.

The reassessment notice under section 148 was examined against the applicable limitation framework for old-regime notices, including the effect of the deeming fiction and the time available to the Revenue after the assessee's reply to the show-cause notice. The crucial issuance date was found to fall beyond the extended deadline, so the notice was time-barred. As a result, the reassessment proceedings could not be sustained and were treated as void ab initio, with the issue decided in favour of the assessee.

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Issues: Whether the notice issued under section 148 of the Income-tax Act, 1961 was barred by limitation, and whether the consequent reassessment proceedings were liable to be quashed.

Analysis: The reassessment process was examined in the light of the Supreme Court's ruling on the effect of the deeming fiction created for old-regime notices and the surviving time available to the Revenue after the assessee's reply to the show-cause notice. The crucial date for issuance of the notice under section 148 was held to be beyond the extended deadline computed on the basis of the applicable limitation framework. Once the notice was found to have been issued after the permissible period, the reassessment proceedings could not survive.

Conclusion: The notice under section 148 was time-barred, and the reassessment proceedings were void ab initio; the issue was decided in favour of the assessee.

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