The dispute concerns reassessment proceedings initiated through orders under Sec. 148A(d) and notices under Sec. 148 with the central issue being limitation/time-bar considering Sec. 149 (as amended w.e.f. 1-4-2021).The Assessee contended that the matter is covered by the Bombay High Court ruling in New India Assurance Co. Ltd. v. ACIT, i.e., notices already time-barred prior to 1-4-2021 cannot be revived by applying Sec. 149(1)(b) effective from 1-4-2021, and reassessments initiated pursuant to Union of India v. Ashish Agarwal would also be beyond time limit.

Revenue agreed with the assessee’s submission before the High Court.

The Hon’ble Bombay High Court quashed Sec. 148A (d) orders and Sec. 148 notices as beyond limitation. The Department despite agreement filed an SLP before the Hon’ble Supreme Court (‘SC’). The Hon’ble SC dismissed the SLP on the ground of unexplained delay.