The HC held that the issuance of the notice under section...

The HC held that the issuance of the notice under section 148A(b) of the Act was beyond the prescribed period of limitation under section 149(1)(a), as the AO issued the notice on the last permissible date but failed to extend the order-passing period under section 148A(d) to the mandatory seven days. The AO's initial decision against reopening the assessment was revised solely based on the specified authority's approval, which did not cure the limitation defect. Since the case did not fall under the extended limitation clause, the notice was invalid. Consequently, the reopening of assessment was barred, and the impugned notice was quashed, affirming that adherence to the limitation period and procedural safeguards under sections 148, 148A, and 149 is mandatory for reopening assessments.