Time-barred reassessment notice under Section 148 quashed after Revenue concession for AY 2015-16.

Reassessment under Section 148 for AY 2015-16 was treated as time barred because the Revenue's concession in Rajeev Bansal required notices issued on or after 1 April 2021 for that year to be dropped as they could not be completed within the relaxation period under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. The notice issued on 5 April 2021 and the consequential Section 148A(d) order therefore could not be sustained, and both were quashed in favour of the assessee.

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Issues: Whether the reassessment notice issued under Section 148 of the Income-tax Act, 1961 and the order under Section 148A(d) of the Income-tax Act, 1961 for Assessment Year 2015-16 were time barred and liable to be quashed.

Analysis: The reassessment proceedings arose from a notice originally issued on 5 April 2021 and later continued through the Section 148A procedure after the decision in Ashish Agarwal. The controlling consideration was the subsequent concession recorded by the Revenue in Rajeev Bansal that, for Assessment Year 2015-16, all notices issued on or after 1 April 2021 had to be dropped as they would not fall for completion within the period prescribed under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. On that basis, the challenged notice and the consequential order could not be sustained.

Conclusion: The reassessment proceedings were held to be time barred and the impugned notice and order were quashed in favour of the assessee.

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