Jurisdiction Before Merits

The Tribunal holds that the reassessment notice issued on 29.07.2022 for AY 2015–16 is barred by limitation under Section 149 and therefore void ab initio, rendering the entire proceeding non-est. 

On the second issue, it holds that disallowance under Section 14A is unsustainable in absence of recorded dissatisfaction by the Assessing Officer. 

The appeals of the assessee are allowed in entirety, reaffirming that jurisdictional compliance is foundational to tax proceedings.