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Issues: Whether the reassessment notice issued under section 148 of the Income-tax Act, 1961 for assessment year 2015-16 was barred by limitation in view of the inapplicability of the TOLA extension.
Analysis: The notice under section 148 was issued on 23.06.2021. It was held that the relaxation under TOLA from 01.04.2021 to 30.06.2021 was not available for the relevant assessment year, and the reopening for assessment year 2015-16 could not be sustained in the extended period. The reassessment proceedings were therefore found to be time-barred.
Conclusion: The reassessment notice was barred by limitation and was quashed.
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