Reassessment limitation under Section 149 controls notice issuance; time for a Section 148A order cannot extend the statutory deadline.

Reassessment notices issued after 1 April 2021 must comply with the amended regime and the mandatory outer limitation for issuing notice under Section 148. For Assessment Year 2015-16, exclusion of the response period under Section 148A(b) and the additional statutory extension fixed the outer date at 9 April 2022; an order under Section 148A(d) and notice issued later were time-barred. The consequential assessment and penalty were therefore quashed. The time allowed to pass an order under Section 148A(d) cannot enlarge the Section 149(1) limitation for issuing a reassessment notice. A Revenue concession in Rajeev Bansal was inapplicable because the proceedings did not rely on the 2020 relaxation legislation.

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Issues: (i) Whether the reassessment notice and consequential assessment for Assessment Year 2015-16 were barred by limitation; (ii) Whether the Revenue's concession concerning reassessment notices in Rajeev Bansal applied independently to invalidate the impugned proceedings.

Issue (i): Whether the reassessment notice and consequential assessment for Assessment Year 2015-16 were barred by limitation.

Analysis: The amended reassessment regime governed a notice issued after 01.04.2021. Although the six-year period from the end of the relevant assessment year expired on 31.03.2022, the time allowed to respond to the notice under Section 148A(b) was excluded under the first proviso to Section 149(1), and the fourth proviso afforded a further seven-day extension. The resulting outer date for passing the order under Section 148A(d) and issuing the notice under Section 148 was 09.04.2022. The order and notice issued on 18.04.2022 exceeded that mandatory outer limit. The period available for passing an order under Section 148A(d) could not override the statutory cap for issuance of the notice under Section 148.

Conclusion: The reassessment notice, consequential assessment, and penalty were time-barred and are quashed, in favour of the assessee.

Issue (ii): Whether the Revenue's concession concerning reassessment notices in Rajeev Bansal applied independently to invalidate the impugned proceedings.

Analysis: The concession was made in the specific context of limitation extensions under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Since the Revenue did not rely on that enactment to sustain these proceedings, which were instead tested under Sections 148, 148A and 149, the concession could not be extended to the present facts. The issue did not affect the relief granted on the independent ground of statutory limitation.

Conclusion: The concession in Rajeev Bansal was not germane to the impugned reassessment proceedings, against the assessee.

Final Conclusion: Reassessment jurisdiction must be exercised within the outer time limit prescribed for issuance of a notice under Section 148, after giving effect only to the statutory exclusions and extensions.

Ratio Decidendi: The time available for an order under Section 148A(d) does not enlarge the mandatory outer limitation under Section 149(1) for issuing a reassessment notice under Section 148.

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