Time-barred reassessment notices for Assessment Year 2015-16 cannot survive where issued after 1 April 2021.

Reassessment notices under Section 148 for Assessment Year 2015-16 issued on or after 1 April 2021 are time-barred in light of the Supreme Court's clarification recorded in Rajeev Bansal. The operative point is the limitation bar: where the notice falls within that category, it is liable to be treated as beyond time, with consequential reassessment action exposed to quashing.

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

Analysis: The assessment year in question was 2015-16. The Supreme Court had clarified that, where the proceedings pertain to Assessment Year 2015-16, reassessment notices issued or proposed to be issued would stand barred by time in light of the concession recorded in Rajeev Bansal. Since the impugned notice was issued on or after 1 April 2021 and related to Assessment Year 2015-16, it fell within the category of time-barred notices referred to by the Supreme Court.

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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