MAHADEO PRASAD BAIS (DEAD) vs INCOME-TAX OFFICER 'A' WARD, GORAKHPUR AND ANR.

The Supreme Court held that Section 150(1) of the Income Tax Act, 1961 applies to notices issued under Section 148 in conjunction with Section 297(2)(d)(ii), thereby lifting the time bar for reassessment. The Court affirmed that the provisions of Section 297(2) are intended to ensure continuity of proceedings following the repeal of the 1922 Act, allowing for reassessment to be initiated despite the lapse of time. Consequently, the appeal of the assessee was dismissed, upholding the High Court's decision that the reassessment notice was valid and not barred by limitation.