Reassessment limitation under amended section 149 bars belated notices after three years unless the extended threshold is met.

Reassessment proceedings initiated after 01.09.2024 must comply with the amended limitation regime in section 149. A notice under section 148 issued beyond three years from the end of the relevant assessment year is without jurisdiction unless the statutory conditions for the extended period are satisfied, including material showing escapement of income of at least the prescribed threshold. For Assessment Year 2015-16, the notice and consequential order were issued after the three-year limit without such material, so they were held unsustainable and quashed.

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Issues: Whether the reassessment notice and consequential order for Assessment Year 2015-16, issued after the amendment to section 149 with effect from 01.09.2024, were sustainable in law.

Analysis: The amended reassessment regime governed proceedings initiated after 01.09.2024. Under the amended section 149, a notice under section 148 could not be issued after three years from the end of the relevant assessment year unless the conditions for the extended period under clause (b) were satisfied. For Assessment Year 2015-16, the notice was issued beyond the three-year period, and the record did not show any material indicating that income escaping assessment amounted to or was likely to amount to Rs. 50,00,000/- or more.

Conclusion: The reassessment notice and the consequential order were not sustainable and were quashed. The issue was decided in favour of the assessee.

Final Conclusion: The writ petition succeeded and the impugned reassessment proceedings for Assessment Year 2015-16 were annulled.

Ratio Decidendi: Reassessment proceedings initiated after 01.09.2024 must satisfy the amended limitation conditions in section 149, and a notice issued beyond three years from the end of the relevant assessment year is without jurisdiction unless the statutory threshold for the extended period is met.

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