01/07/2026
# # # **CASE SUMMARY**
**Issue:** Whether the reassessment notice for AY 2017β18 was barred by limitation under Section 149(1).
**Held:**
The High Court held that the time consumed in considering replies to the notice under Section 148A(b), including adjournments sought by the assessee, is excluded while computing the limitation period under the fifth proviso to Section 149(1). Consequently, the notice issued under Section 148 was held to be valid. The Supreme Court dismissed the SLP, affirming the High Court's view.
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# # # **EXPERT ADVICE**
β Carefully monitor all timelines in reassessment proceedings.
β Time taken due to adjournments requested by the assessee may extend the limitation period.
β Respond to notices under Section 148A(b) promptly to avoid unnecessary delays.
β Before challenging a reassessment notice on limitation grounds, verify the effect of the provisos to Section 149(1).
β Maintain complete records of notices, replies, and adjournment requests, as these can be crucial in litigation.
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# # # **KEY TAKEAWAY**
**Delay attributable to proceedings under Section 148A(b), including assessee-requested adjournments, may be excluded while computing limitation under Section 149(1), thereby validating a reassessment notice that might otherwise appear time-barred.**
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