Time-barred reassessment proceedings under section 148 were unsustainable, with reopening for AY 2015-16 failing on limitation.

Reassessment for AY 2015-16 was found time-barred because the notice under section 148, issued on 29.06.2021, and the consequent proceedings under sections 148A and 148 fell beyond the permissible limitation period. The appellate authority had already quashed the reopening on that basis, and the ITAT found no infirmity in that view. The reopening could not therefore be sustained, and the Revenue's challenge failed.

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Issues: Whether the reassessment proceedings for assessment year 2015-16 were barred by limitation and therefore invalid.

Analysis: The reassessment related to assessment year 2015-16. The appellate authority had quashed the reassessment on the ground that the notice under section 148 issued on 29.06.2021, and the subsequent proceedings under section 148A and section 148, were time-barred. The Tribunal found no infirmity in that conclusion and accepted the view that the reopening for the relevant assessment year could not be sustained.

Conclusion: The reopening was held to be barred by limitation and the Revenue's challenge failed.

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