Reassessment notice service after the cut-off date cannot sustain proceedings when section 148A procedure was not followed.

Reassessment proceedings under the old regime were found unsustainable where the notice under section 148 was dated 31.03.2021 but was communicated to the assessee only on 16.04.2021, and no material was produced to dispute that timeline. The Tribunal applied the principle that mere generation of a notice on the ITBA portal does not validate reassessment once service and communication occur after the cut-off date, and the procedure under section 148A was not followed. On that basis, the reassessment was vitiated, the additional ground was allowed, and the reassessment order was quashed in favour of the assessee.

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Issues: Whether the reassessment proceedings were invalid and the reassessment order liable to be quashed on the ground that the notice under section 148 was issued within time but served after 31.03.2021, and the procedure under section 148A was not followed.

Analysis: The assessee produced the notice and ITBA portal screenshots showing that the notice under section 148 was dated 31.03.2021 but was communicated to the assessee only on 16.04.2021. The Revenue did not place any material to dispute these facts. The Tribunal applied the principle that mere generation of the notice on the portal was not enough to sustain proceedings under the old regime once dispatch and communication occurred after the cut-off date, and the proceedings could not be saved as having been validly initiated under the old framework.

Conclusion: The reassessment proceedings were held to be vitiated, the additional ground was allowed, and the reassessment order was quashed in favour of the assessee.

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