Reassessment limitation under Section 148A rendered reopening invalid when notice and order were issued beyond the statutory period.

Reassessment proceedings were time-barred because the notice treated as a Section 148A(b) show-cause notice and the consequential Section 148A(d) order were issued after expiry of the statutory period applicable after the Supreme Court's directions in Ashish Agarwal. The assessee had responded within the permitted time, but the reopening steps were still taken beyond the permissible limit, so the notice under Section 148 and the order under Section 148A(d) were invalid and liable to be set aside. The separate objection relating to approval by the specified authority was not adjudicated because limitation was dispositive.

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Issues: Whether the notice issued under Section 148 and the order passed under Section 148A(d) of the Income-tax Act were barred by limitation and therefore invalid.

Analysis: The appeal turned on the timeline governing reassessment after the Supreme Court's directions in Ashish Agarwal. The original notice was treated as a show-cause notice under Section 148A(b), the assessee responded within the permitted time, and the consequential order under Section 148A(d) had to be passed within the period prescribed by the statutory regime then applicable. On the facts, the notice and the order were issued after expiry of the permissible period, making the reassessment action time-barred. Since the limitation issue was , the separate objection regarding approval by the specified authority was not adjudicated.

Conclusion: The notice under Section 148 and the order under Section 148A(d) were barred by limitation and were liable to be set aside.

Final Conclusion: The reassessment proceedings could not be sustained because the jurisdictional steps taken for reopening were beyond the permissible statutory time limit.

Ratio Decidendi: A reassessment notice and the consequential order are invalid when issued beyond the statutory limitation period governing reopening proceedings.

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