Limitation for section 148 reassessment notice for assessment year 2015-16 rendered the reopening time-barred and quashed.

For assessment year 2015-16, a notice issued under section 148 on 31.07.2022 was treated as barred by limitation under the limitation regime read with the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, as applied in the line of decisions following the Revenue's concession in Rajeev Bansal. The Tribunal held that notices for that year issued on or after 01.04.2021 would not survive, so the reassessment notice was time-barred. The reassessment proceedings and the assessment order were therefore quashed in favour of the assessee.

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Issues: Whether the notice issued under section 148 for assessment year 2015-16 was barred by limitation and, if so, whether the reassessment proceedings and assessment order were liable to be quashed.

Analysis: The assessment year in question was 2015-16. The notice under section 148 was issued on 31.07.2022. The Tribunal noted that the issue stood covered by the consistent line of decisions following the Revenue's concession before the Supreme Court in Rajeev Bansal that, for assessment year 2015-16, notices issued on or after 01.04.2021 would not survive under the limitation regime read with the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. On that basis, the reassessment notice was treated as time-barred.

Conclusion: The notice under section 148 was held to be barred by limitation and was quashed. Consequently, the reassessment proceedings and the assessment order were also quashed, in favour of the assessee.

Ratio Decidendi: For assessment year 2015-16, a reassessment notice issued on or after 01.04.2021 is time-barred where the limitation period, as applied in light of the Revenue's concession and the TOLA framework, has expired.

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