Time-barred reassessment notices under the new regime were held invalid, quashing proceedings founded on them.

Reassessment notices under section 148 were issued under the substituted reassessment regime and had to be tested against the transitional relaxation under TOLA and the Supreme Court's directions on deemed notice and supply of material. On the recorded facts, the notices dated 26.07.2022 and 30.07.2022 were issued beyond the surviving limitation period, rendering them invalid in law. As the notices themselves were time-barred, the reassessment proceedings founded on them could not be sustained and were quashed in all the appeals.

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Issues: Whether the notices issued under section 148 for the relevant assessment years were barred by limitation, and whether the consequent reassessment proceedings could survive.

Analysis: The notices were examined against the extended timelines arising from the substituted reassessment regime, the transitional relaxation under TOLA, and the time allowed after the deemed notice and supply of material in terms of the Supreme Court directions. On the facts recorded, the notices dated 26.07.2022 and 30.07.2022 were issued beyond the surviving limitation period. Once the notices were found to be invalid in law, the reassessment proceedings based on them could not be sustained.

Conclusion: The notices under section 148 were held to be time-barred and invalid, and the reassessment proceedings were quashed in all the appeals.

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