Amended reassessment limitation under Section 149 barred invalid notices issued beyond three years without the statutory threshold.

Reassessment proceedings must conform to the amended limitation regime under Section 149 of the Income-tax Act, 1961. Notices issued beyond three years from the end of the relevant assessment year are without jurisdiction unless the extended condition in Section 149(1)(b) is met. For Assessment Year 2015-16, the record did not show escaped income of Rs. 50,00,000 or more, so the extended period was unavailable. The show-cause notice under Section 148A(b), the order under Section 148A(d), and the notice under Section 148 were therefore quashed and set aside.

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Issues: Whether the show-cause notice under Section 148A(b), the order under Section 148A(d), and the notice under Section 148 for Assessment Year 2015-16 were valid in view of the amended limitation regime under Section 149 of the Income-tax Act, 1961.

Analysis: The challenge turned on the applicability of the amended reassessment provisions with effect from 01.09.2024. The Court held that reassessment action must conform to the amended Section 149, and that notices issued beyond the period prescribed under Section 149(1)(a) are without jurisdiction unless the conditions under Section 149(1)(b) are satisfied. For Assessment Year 2015-16, the impugned notice was issued beyond three years from the end of the relevant assessment year, and the record did not disclose material showing escaped income of Rs. 50,00,000 or more so as to attract the extended period under Section 149(1)(b).

Conclusion: The reassessment proceedings were held to be unsustainable and the impugned show-cause notice, order under Section 148A(d), and notice under Section 148 were quashed and set aside.

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