Transitional reassessment notices must fall within the surviving limitation period, or they are invalid and time-barred.

Transitional reassessment notices under the new regime must be issued within the surviving limitation period after applying statutory exclusions and the Supreme Court-recognised time computation. Where a notice under the old regime had already triggered the transition, the Assessing Officer could proceed under sections 148, 148A and 149 only within the remaining time available. Because the impugned notice was issued beyond that surviving period, the notice and the consequent reassessment proceedings were treated as time-barred and invalid.

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

Analysis: The governing principle applied was that, where a notice under the old regime had triggered the transitional framework, the Assessing Officer could proceed under the new regime only within the surviving time available after exclusions recognised by the Supreme Court. The reassessment machinery under sections 148, 148A and 149 had to be completed within that surviving period, and the later notice had to fit within the permissible time limit. Since the impugned notice was issued beyond that surviving time, the reassessment was treated as time-barred.

Conclusion: The issue was decided in favour of the assessee, and the notice and reassessment proceedings were held to be barred by limitation.

Ratio Decidendi: Transitional reassessment notices issued under the new regime must be issued within the surviving limitation period available after applying the statutory exclusions and the Supreme Court-recognised time computation; a notice issued beyond that period is invalid.

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