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Reassessment notices under Section 148 must be issued within the applicable limitation period. The original six-year period expired on 31 March 2020, while the relevant extension notification covered only notices whose original limitation expired on 31 March 2021; it therefore did not extend time for a notice issued on 1 April 2021. Such notice was time-barred, requiring the consequential assessment orders to be set aside. Section 292BB addresses defects in service where an assessee participates in proceedings despite ineffective service; it cannot validate a reassessment notice issued after the statutory limitation period.
Reassessment notices under Section 148 must be issued within the applicable limitation period. The original six-year period expired on 31 March 2020, while the relevant extension notification covered only notices whose original limitation expired on 31 March 2021; it therefore did not extend time for a notice issued on 1 April 2021. Such notice was time-barred, requiring the consequential assessment orders to be set aside. Section 292BB addresses defects in service where an assessee participates in proceedings despite ineffective service; it cannot validate a reassessment notice issued after the statutory limitation period.
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