Limitation for reassessment notices under section 148 must be computed under the post-Ashish Agarwal framework and Rajeev Bansal rules.

A reassessment notice under section 148 was held time barred where the surviving limitation had to be computed under the post-Ashish Agarwal framework and the Supreme Court's guidance in Rajeev Bansal, including the exclusions in the third proviso to section 149 and the limited extension in the fourth proviso. On that computation, the notice issued on 19.07.2022 fell beyond the available period, and the argument that section 148A(d) independently extended the time for completion was rejected. The notice was therefore invalid, and the reassessment proceedings and consequential assessment order were quashed on limitation grounds.

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Issues: Whether the notice issued under section 148 and the consequential reassessment proceedings were barred by limitation and therefore void ab initio.

Analysis: The assessment year in question fell within the regime where the original limitation under section 149 had expired. The notice first issued in June 2021 was treated in the post-Ashish Agarwal framework as a deemed notice under section 148A(b), and the surviving time available to the Revenue had to be computed in accordance with the Supreme Court's ruling in Rajeev Bansal, including the exclusions under the third proviso to section 149 and the limited extension under the fourth proviso. On that computation, the notice under section 148 issued on 19.07.2022 was beyond the surviving period. The contention that section 148A(d) independently extended the time for completion was rejected.

Conclusion: The notice under section 148 was held to be time barred and invalid. The reassessment proceedings and the assessment order passed in consequence were quashed, and the assessee succeeded on the limitation ground.

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