Reassessment notice limitation: time-barred section 148 notice failed, and the reopening proceedings were quashed.

A notice under section 148 issued for assessment year 2013-14 was held time-barred after applying the limitation framework in section 149 of the Income-tax Act, 1961, including the relaxation provisions and the Supreme Court ruling in Rajeev Bansal. Because the permissible period for issuing the reassessment notice had already expired when the notice was issued on 31.07.2022, the statutory foundation for reopening failed. The reassessment proceedings initiated on that notice were therefore quashed.

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Issues: Whether the notice issued under section 148 for the assessment year 2013-14 was barred by limitation and, if so, whether the reassessment proceedings and consequential assessment were liable to be quashed.

Analysis: The notice dated 31.07.2022 was examined against the limitation framework under section 149 of the Income-tax Act, 1961 as applied to the reassessment regime, including the effect of the relaxation provisions and the Supreme Court ruling in Rajeev Bansal. On the facts recorded, the permissible period for issuing notice had already expired when the notice under section 148 was issued. Once the notice was found to be beyond the statutory time limit, the foundation for the reassessment proceedings failed.

Conclusion: The notice under section 148 was time-barred, and the reassessment proceedings initiated on that basis were quashed.

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