Reassessment notice was invalid if it was issued beyond the calculated “surviving time” or “last date” time limit

Held: AO issued a notice under section 148 for AY 2014–15, invoking the extended limitation period under TOLA, 2020. Brief facts of the case are that the respondent Assessing Officer issued notice dated 24. The impugned notices issued under section 148 of the Act are accordingly quashed and set aside being invalid having been issued beyond the ‘surviving time’. The order under section 148A(d) of the Act as well as notice under section 148 of the Act was issued on 24.08.2022. All notices issued beyond the surviving period are time barred and liable to be set aside.”10.