Reassessment notice limitation bars later proceedings where the original notice is time-barred and jurisdictionally void.

A reassessment notice for Assessment Year 2015-16 issued on or after 01.04.2021 was held time-barred and void, because the limitation defect was jurisdictional and could not be cured by later steps under the reassessment scheme. The subsequent notice under section 148A, the order under section 148A(d), and the reassessment order all failed with the original notice, since the transitional deeming fiction did not revive a notice already barred by limitation. As a result, the reassessment proceedings and resulting additions were quashed, and the merits of the additions were left unexamined as academic.

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Issues: Whether the reassessment notice issued for Assessment Year 2015-16 after 01.04.2021 was barred by limitation and whether the subsequent notice under section 148A, order under section 148A(d), and reassessment order could survive; and whether the additions on merits required adjudication once the reassessment foundation was found invalid.

Analysis: The reassessment notice under section 148 was issued on 07.06.2021 for Assessment Year 2015-16. The governing legal position, as applied by the Court, was that notices for this assessment year issued on or after 01.04.2021 fall outside the permissible limitation period. Once the original notice is time-barred, the defect is jurisdictional in nature and cannot be cured by subsequent procedural steps, including proceedings under section 148A or the reassessment order passed thereafter. The deeming fiction applied in the transitional reassessment framework does not extend or revive a notice that is already barred by limitation.

Conclusion: The reassessment notice was invalid and the consequential proceedings could not survive.

Final Conclusion: The reassessment proceedings and the resulting additions were quashed on the ground of limitation, and the merits of the additions were left unexamined as academic.

Ratio Decidendi: For Assessment Year 2015-16, a reassessment notice issued on or after 01.04.2021 is time-barred and void, and such a jurisdictional defect cannot be cured by subsequent proceedings under the reassessment scheme.

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