Income Tax reassessment notices for AY 2015-16 issued after April 1, 2021, are time-barred and invalid.

The petitioner challenged a reassessment notice issued under Section 148 of the Income Tax Act, 1961, dated 04.06.2021, for Assessment Year (AY) 2015-16.

The Revenue initially issued the notice under the old regime, relying on the extension provided by the Taxation and Other Laws (Relaxation of Certain Provisions) Act, 2020 (TOLA).

Following the Supreme Court’s decision in *Ashish Agarwal*, the notice was treated as a show-cause notice under the new Section 148A(b), leading to a subsequent order under Section 148A(d) and a fresh notice under Section 148 in July/August 2022.

The petitioner contended that for AY 2015-16, the reassessment was time-barred as it fell outside the permissible limits defined by the Supreme Court in subsequent rulings.

Whether the notice issued under Section 148 for Assessment Year 2015-16 after 01.04.2021 is hit by the limitation period prescribed under Section 149 of the Act.

The Court applied Section 149 of the Income Tax Act (as amended w.e.f. 01.04.2021), which governs the time limits for reopening assessments.

It relied heavily on the Supreme Court precedents in *Union of India v. Rajeev Bansal* (2024), which held that for AY 2015-16, the three-year period expired on 31.03.2019 and the six-year period expired on 31.03.2022, effectively excluding such notices from the protective umbrella of TOLA extensions.

The Court also followed *Deepak Steel and Power Ltd v. CBDT* (2025), where the Revenue conceded that notices for AY 2015-16 issued on or after April 1, 2021, must be dropped.

The Court noted that the Revenue had already conceded before the Supreme Court in *Rajeev Bansal* that notices for AY 2015-16 issued after 01.04.2021 are invalid because they do not fall within the completion period prescribed under TOLA.

For AY 2015-16, the statutory six-year limit under the old regime would have expired after the TOLA period began, but under the new regime (w.e.f. 01.04.2021), the notice must comply with the new Section 149.

Since the impugned notices in this case were finalized in July/August 2022 (after the 31.03.2022 cutoff for the six-year limit) or were originally issued during the interregnum (01.04.2021 to 30.06.2021) without meeting the revised criteria for AY 2015-16, they are legally unsustainable.

It held that all reassessment notices for AY 2015-16 issued on or after 01.04.2021 are invalid as they are time-barred and do not benefit from TOLA relaxations.

Rule made absolute.