Limitation for reassessment notices under the Income-tax Act rendered the notice invalid when issued after the statutory deadline.

A reassessment notice under the Income-tax Act was held time-barred because it was issued after the last permissible date for the relevant assessment year. The notice for Assessment Year 2015-16 was issued on 11 April 2022, whereas the limitation period expired on 31 March 2022. On that basis, the notice was liable to be quashed, and the consequential assessment order also fell.

---

---

Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 was barred by limitation and liable to be quashed.

Analysis: The notice was issued for Assessment Year 2015-2016. The Court recorded that the last permissible date for issuing the notice was 31.03.2022, whereas the impugned notice was issued on 11.04.2022. The petitioner accepted the Department's stand, in the light of the position placed before the Supreme Court, that the notice had been issued beyond the six-year period.

Conclusion: The notice was barred by limitation and was liable to be set aside, along with the consequent assessment order.

---