Reassessment limitation bars jurisdiction where notice under section 148 is issued beyond the surviving statutory period.

Reassessment proceedings were found to be time barred because the notices under section 148A(d) and section 148 were issued beyond the surviving limitation period under section 149(1), as read with the transitional relaxation regime. The tribunal treated the delayed initiation as a jurisdictional defect, holding that a notice issued outside the permissible time cannot sustain reassessment under section 147. The assessment framed on that basis was therefore unsustainable, and the addition arising from the quashed assessment did not survive.

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Issues: Whether the reassessment proceedings and the notice issued under section 148 were barred by limitation and therefore liable to be quashed.

Analysis: The relevant dates were examined against the limitation framework under the substituted reassessment regime and the directions governing the transition from the old to the new regime. On the admitted facts, the notice under section 148A(d) and the consequential notice under section 148 were issued beyond the surviving time available under section 149(1) read with the relaxation provided by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Once the reassessment notice was beyond the permissible period, the initiation itself suffered from a jurisdictional defect and could not be sustained. The assessment framed under section 143(3) read with section 147 was therefore unsustainable.

Conclusion: The reassessment proceedings were held to be time barred and invalid, and the addition arising from the quashed assessment did not survive.

Ratio Decidendi: A reassessment notice issued beyond the surviving limitation period under the Income-tax Act, 1961 read with the statutory relaxation regime is without jurisdiction and must be set aside.

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