Reassessment limitation under TOLA bars post-1 April 2021 notices for Assessment Year 2015-16, invalidating the assessment.

Reassessment notice issued for Assessment Year 2015-16 after 1 April 2021 was treated as beyond the limitation period, because TOLA did not extend the time available for such action in the circumstances. The Tribunal applied the binding position in Rajeev Bansal and noted the Revenue's concession that notices for that assessment year issued on or after 1 April 2021 would not survive under TOLA. The reassessment proceedings were therefore held time barred, and the assessment made pursuant to them was unsustainable and invalid in favour of the assessee.

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Issues: Whether the reassessment notice issued for Assessment Year 2015-16 under the post-1 April 2021 regime was barred by limitation and the reassessment proceedings were therefore invalid.

Analysis: The notice under section 148 was issued after 1 April 2021 and the case fell beyond the period of completion covered by TOLA. The Tribunal followed the binding position emerging from the Supreme Court's decision in Rajeev Bansal and the Revenue's own concession that notices for Assessment Year 2015-16 issued on or after 1 April 2021 would not survive under TOLA. On that basis, the reassessment proceedings were treated as time barred and the assessment made pursuant thereto was held unsustainable.

Conclusion: The reassessment notice and the consequent assessment were held to be barred by limitation and invalid, in favour of the assessee.

Ratio Decidendi: Where reassessment notices for a particular assessment year are issued beyond the period permitted under the applicable limitation framework and TOLA does not extend that period, the reassessment proceedings are invalid and the assessment founded on them cannot be sustained.

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