Reassessment limitation under section 153(2) rendered the reassessment orders time-barred after delayed completion under section 147.

A reassessment initiated under section 147 following service of notice under section 148 must be completed within the limitation period prescribed by section 153(2), counted from the end of the financial year in which the notice is served. On the admitted dates, the reassessments were completed after the permissible period, so the limitation objection succeeded and the reassessment orders were quashed as time-barred. The merits-based grounds were not examined because they had become academic after the jurisdictional defect on limitation was established.

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Issues: Whether the reassessments completed under section 147 read with section 143(3) of the Income-tax Act, 1961 for the relevant assessment years were barred by limitation under section 153(2) of the Income-tax Act, 1961.

Analysis: Notice under section 148 of the Income-tax Act, 1961 had been served on 27.03.2014. The statutory period under section 153(2) required completion of the reassessments within one year from the end of the financial year in which such notice was served. On the admitted dates, the reassessments were completed after the permissible period. The challenge to limitation thus succeeded, and the remaining merits-based grounds were not adjudicated as they had become academic.

Conclusion: The reassessments were held to be time-barred and were quashed in favour of the assessee.

Final Conclusion: The appeals succeeded on the jurisdictional issue of limitation, resulting in annulment of the reassessment orders while leaving the other grounds open as academic.

Ratio Decidendi: A reassessment under section 147 of the Income-tax Act, 1961 must be completed within the limitation period prescribed by section 153(2), counted from the end of the financial year in which notice under section 148 is served; failure to do so renders the reassessment time-barred.

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