High Court Invalidates Tax Reassessment Notice Due to Limitation Period Violation and Lack of Substantial New Evidence

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....HC held that the reassessment notice issued by the AO was invalid. The notice was beyond the prescribed limitation period and constituted an impermissible review of a concluded assessment. The AO's attempt to reopen the assessment based on audit observations did not meet the legal threshold for "escaped assessment" under Section 147 and Section 148A. The court found no additional material suggesting income escaped assessment, and the notice was effectively an attempt to change the original assessment order. The reassessment proceedings were consequently quashed, with the limitation period being a critical factor in the court's determination.....