Court Invalidates Tax Notice Issued Post-Limitation Period; COVID-19 Extension Misapplied, Renders Order Illegal.

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....The High Court held that the Assessing Officer lacked jurisdiction to issue a notice u/s 148 on 25 July 2022 for the assessment year 2013-14, as the limitation period had expired on 31 March 2020, further extended till 31 March 2021 due to the COVID-19 pandemic. The amendment to Section 149(1)(b) by the Finance Act 2022, effective from 1 April 2022, was not applicable to the reassessment for the assessment year 2013-14. The Assessing Officer erroneously applied the amended provisions while issuing the notice, overlooking the expiry of the limitation period. Consequently, the assessment order dated 26 May 2023, passed based on the inherently jurisdictional notice, was rendered illegal. Applying the principles laid down in the New India Assurance Co. Ltd. case, the High Court allowed the petition, recognizing the Assessing Officer's lack of jurisdiction.....