Reassessment limitation under Section 149 upheld where deemed reply date made the Section 148A(d) notice timely.

A reassessment order under Section 148A(d) and the consequential notice under Section 148 were within limitation because the assessee's adjournment request was declined and 15.04.2024 was treated as the deemed date of reply. On that basis, the Assessing Officer had seven days to complete the action under the fifth and sixth provisos to Section 149, and the order and notice issued on 16.04.2024 fell within the permitted period. The limitation challenge therefore failed.

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Issues: Whether the order under Section 148A(d) and the consequential notice under Section 148 of the Income-tax Act, 1961 were barred by limitation under the fifth and sixth provisos to Section 149.

Analysis: The notice under Section 148A(b) was issued on 28.03.2024 and the assessee was granted time to respond, but sought adjournments on 05.04.2024 and 15.04.2024. The request for adjournment was declined, and the date of 15.04.2024 was treated as the deemed date of filing reply. Once that date was taken as the relevant date, the Assessing Officer had seven days to pass the order under Section 148A(d) and issue notice under Section 148. The order and notice were issued on 16.04.2024, which was within the permissible period.

Conclusion: The reassessment action was within limitation and the challenge failed.

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