Limitation for reassessment notice under the Income-tax Act barred a time-expired reopening, and TOLA could not extend it.

A reassessment notice for Assessment Year 2015-16 issued under the Income-tax Act, 1961 was treated as time-barred under the limitation scheme in Section 149, and the corresponding assessment under Sections 147 and 144B could not be sustained. The text further states that TOLA did not extend the limitation for a notice under Section 148 issued on or after 1 April 2021 for that year, so the reassessment order was correctly quashed and the Revenue's challenge failed.

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Issues: Whether the reassessment notice and assessment for Assessment Year 2015-16 were barred by limitation and whether the benefit of TOLA could apply to a notice issued under the reassessment provisions for that year.

Analysis: The appeal concerned an assessment made under Section 147 read with Section 144B of the Income-tax Act, 1961. The reassessment notice under Section 148 for Assessment Year 2015-16 was held to be hit by limitation under Section 149. It was further noted that TOLA did not apply to a notice issued under Section 148 for that assessment year on or after 1 April 2021, and therefore the assessment order could not be sustained.

Conclusion: The reassessment was correctly quashed, and the Revenue's challenge failed.

Final Conclusion: The assessee succeeded in sustaining the annulment of the reassessment order, and the Revenue's appeal did not survive.

Ratio Decidendi: A reassessment notice for Assessment Year 2015-16 issued under the Income-tax Act, 1961 after the prescribed limitation period is invalid, and TOLA cannot extend the limitation for such notice issued on or after 1 April 2021.

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