> **Order:** ITA No. 3480/Del/2025 (ITAT Delhi), Assessment Year 2015-16, pronounced 31.12.2025.

## Facts

The appeal was preferred against the final assessment order dated 11.03.2025 passed under section 147 read with section 144C(13), pursuant to the Dispute Resolution Panel order dated 18.02.2025 for AY 2015-16.
Grounds 3 and 4 contended that the reassessment proceedings initiated under sections 147/148/148A are bad in law and the consequent order liable to be quashed.
The timeline on record: the original section 148 notice (unamended law) was issued 08.04.2021; a section 148A(b) notice followed 01.06.2022 pursuant to the Supreme Court in UOI vs. Ashish Agarwal; the assessee replied in June 2022; the section 148A(d) order and the impugned section 148 notice are both dated 29.07.2022.

## Issue

Whether a section 148 notice dated 29.07.2022 for AY 2015-16, issued after 01.04.2021, is barred by limitation under section 149.

## Holding

The Tribunal recorded the Revenue's concession in UOI vs. Rajeev Bansal that "for the assessment year 2015-2016, all notices issued on or after April 1, 2021 will have to be dropped as they will not fall for completion during the period prescribed under the Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020".
Since the impugned notice was issued after 01.04.2021, "we hold that the impugned notice is bad in law".
Consequently the assessment order dated 11.03.2025 passed in pursuance of that notice "is also bad in law and hence quashed".
Grounds 3 and 4 were allowed, the other grounds kept academic, and the appeal allowed.

## Why a client would care

Before arguing reassessment on merits for AY 2015-16, check the section 148 notice date: a notice issued on or after 01.04.2021 fails at the threshold on this reasoning.

## Questions clients ask

**Q1. My section 148 notice for AY 2015-16 is dated 29.07.2022 — what did the Tribunal do with it?**

It held the notice bad in law and quashed the 11.03.2025 assessment passed in pursuance of it.

**Q2. Why did the notice fail?**

The Tribunal recorded the Revenue’s concession in UOI vs. Rajeev Bansal that for AY 2015-16 all notices issued on or after 01.04.2021 had to be dropped, because they could not be completed within the relaxed period.

**Q3. Did it decide whether the addition was taxable?**

No — grounds 3 and 4 were allowed and the other grounds were kept academic.

## Disclaimer

*This note summarises a Tribunal order for general information. It is not professional advice and does not predict the outcome of any other case. Tax and company-law positions depend on facts and dates; take a written opinion before you act. Harun Raaj & Associates is a Chartered Accountants firm in Visakhapatnam.*

Canonical: https://www.harunraaj.com/blog/itat-s-148-notice-for-ay-2015-16-issued-after-01-04-2021-3480-del-2025