Surviving period computation cannot be extended beyond the one time 30 day window; post-window reopening notices are time barred.

The note addresses limitation for reopening assessments under Section 148, holding that a one-time 30-day window granted to the Revenue to furnish reasons/material cannot extend or reset the surviving period computation set out in Rajeev Bansal; the surviving period must be calculated by adding the Department's allowed period and the assessee's reply period without further extensions. Consequently, any notice issued after that one-time window and reliance on additional provisional days to enlarge the surviving period are impermissible, rendering such post-window notices and resulting assessment orders time-barred and liable to be quashed.

---

---

Issues: Whether the notice under Section 148 of the Income-tax Act, 1961 dated 30.07.2022 and the consequential assessment and related orders are time-barred under the limitation calculus (surviving period) as laid down by the Supreme Court in Rajeev Bansal, having regard to the 30-day window granted in Ashish Agarwal for providing reasons/material.

Analysis: The controlling authorities establish a two-step timeline: (i) Ashish Agarwal granted a one-time 30-day period from 04.05.2022 for the Revenue to furnish information/material, and (ii) Rajeev Bansal prescribes computation of the surviving period by adding the period allowed to the Department and the period allowed to the assessee to reply (four weeks plus two weeks). Any notice issued by the Department beyond the one-time 30-day window under Ashish Agarwal cannot be used to extend or reset the surviving period. A fresh notice dated 26.07.2022 issued after the Ashish Agarwal window cannot lawfully extend limitation; reliance on the fourth proviso to Section 148A to claim an additional seven days is inconsistent with the Rajeev Bansal mechanism which defines the surviving period without such further extension.

Conclusion: The notice under Section 148 dated 30.07.2022 and the consequential orders, including the assessment order dated 29.01.2026, are time-barred and are quashed. The writ petition is allowed insofar as it seeks quashing of the said notice, the order under Section 148A(d), the second notice dated 26.07.2022, the order disposing objections dated 13.01.2026, the assessment order dated 29.01.2026 and consequential demand and penalty notices.

---