Section 148 notice for Assessment Year 2015-16 held time-barred under the Supreme Court concession in Rajeev Bansal.

A notice issued under Section 148 for Assessment Year 2015-16 was treated as time-barred because it had been issued on or after 1 April 2021, bringing the matter within the concession recorded before the Supreme Court in Rajeev Bansal. Once the assessment year and the date of issue were admitted, no further adjudication was required on limitation, and the challenge to the notice succeeded. The notice was set aside, and all consequential action taken pursuant to it was quashed.

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Issues: Whether the notice issued under Section 148 for Assessment Year 2015-16 was barred by limitation and liable to be quashed.

Analysis: The matter was revived in view of the Supreme Court's remand in connected litigation and the admitted position that the impugned notice had been issued on or after 1 April 2021 for Assessment Year 2015-16. In such cases, the governing concession recorded before the Supreme Court in Rajeev Bansal applied, and no further adjudication was required once the assessment year was found to be 2015-16. The challenge to the notice therefore succeeded on the ground of limitation.

Conclusion: The notice under Section 148 was held to be time-barred and was set aside, and all consequential action taken pursuant to it was quashed.

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