Income-tax limitation periods extended where searches or requisitions trigger transfer-pricing references and for affected third parties. Amendments to section 153B extend limitation periods where the last search or requisition occurred in or after the 2009-10 financial year and a reference under section 92CA is made, treating two years as three years; for persons under section 153C the limitation is thirty-six months from the end of the financial year of the last search/requisition or twenty-four months from handover of seized/requisitioned materials to the Assessing Officer, whichever is later. The Explanation clarifies tolling for audit directions, exchange-of-information requests, and references under section 144BA concerning impermissible avoidance arrangements.
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Income-tax limitation periods extended where searches or requisitions trigger transfer-pricing references and for affected third parties.
Amendments to section 153B extend limitation periods where the last search or requisition occurred in or after the 2009-10 financial year and a reference under section 92CA is made, treating two years as three years; for persons under section 153C the limitation is thirty-six months from the end of the financial year of the last search/requisition or twenty-four months from handover of seized/requisitioned materials to the Assessing Officer, whichever is later. The Explanation clarifies tolling for audit directions, exchange-of-information requests, and references under section 144BA concerning impermissible avoidance arrangements.
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