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Every assessment has a time limit. A notice issued beyond the time limit is barred by limitation and legally void, this is a complete defence even if the underlying tax demand is substantively correct.
Tax notices + litigation · Faceless Assessment
Time limits and limitation: when a notice becomes invalid
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Provisions
IT Act, Sec 153 (now 286) | Sec 148 (now 280) time limits | Finance Act 2021
Analysis
Key limitation periods: • Sec 143(3) (now Sec 270(10), Income-tax Act 2025) assessment: must be completed within 12 months from end of AY (for AY 2023-24 → by March 31, 2025) • 148 reassessment: 3 years from end of AY for income escaped ≤₹50L; 10 years for >₹50L (with specified conditions) • 154 rectification: 4 years from end of AY • CIT(A) appeal: 30 days from date of assessment order. Always check the notice date against the limitation period first, before doing anything else.
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