Time-barred reassessment notice invalidated the jurisdictional basis, making the consequential assessment void.

A reassessment notice issued under section 148 was time-barred because it could have been issued only up to 14.06.2022 but was actually issued on 30.06.2022. The Tribunal treated the late notice as invalid, and once the jurisdictional foundation failed, the reassessment proceedings and the consequential assessment could not survive in law. The additional ground therefore succeeded, and the assessment order was treated as void.

---

---

Issues: Whether the reassessment notice under section 148 of the Income-tax Act, 1961 was time-barred and, if so, whether the reassessment proceedings and consequential assessment were void.

Analysis: The appeal turned on the additional ground challenging the legality of the reassessment. On the dates placed before the Tribunal, the notice under section 148 could have been issued only up to 14.06.2022, but it was actually issued on 30.06.2022. The Tribunal held that the notice was beyond the permissible time limit and therefore invalid. Once the notice itself was barred by limitation, the assumption of jurisdiction failed, and the assessment made pursuant to such notice could not stand in law.

Conclusion: The reassessment notice was held to be time-barred, the jurisdictional foundation of the reassessment was held to be illegal, and the consequential assessment order was treated as void. The additional ground succeeded and the appeal was allowed.

---