Reopening notice limitation under Section 148: amended procedure could not revive a time-barred notice for the assessment year.

Reopening under Section 148 was examined against the limitation applicable to Assessment Year 2015-16. The Tribunal noted that the notice was issued on 04.04.2022 after proceedings under Section 148A(b) and an order under Section 148A(d), but the first proviso to Section 149(1) controlled because the relevant assessment year had already crossed the earlier six-year outer limit. It applied the settled principle that the amended longer limitation cannot revive a notice already barred under the pre-amendment regime, and that the later stages under Sections 148A(b) and 148A(d) do not extend limitation once it has expired. The notice was held time-barred and liable to be quashed.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 was barred by limitation for Assessment Year 2015-16.

Analysis: The notice under Section 148 was issued on 04.04.2022 after proceedings under Section 148A(b) and an order under Section 148A(d). The relevant assessment year began on or before 01.04.2021, so the first proviso to Section 149(1) governed the outer limit for reopening. The Tribunal applied the settled position that the amended longer period cannot revive a notice already time-barred under the earlier regime, and that the later stages under Sections 148A(b) and 148A(d) do not extend the basic limitation where the six-year limit had already expired.

Conclusion: The notice under Section 148 was held to be barred by limitation and liable to be quashed.

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