Time limit for reopening assessments: longer window where escaped income represented as asset triggers extended limitation. No notice under section 148 may be issued after three years from the end of the relevant assessment year, except that where the Assessing Officer has books, documents or evidence showing escaped income represented as an asset, a longer limitation of up to ten years applies; assets include immovable property, shares and securities, loans and advances, and bank deposits. Transitional protections preserve pre-existing time-barred cases for years beginning on or before 1 April 2021; search-related exceptions for actions on or before 31 March 2021 apply; time allowed for show-cause responses or stays is excluded and, if necessary, the remaining period for the Assessing Officer is extended to seven days.
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Provisions expressly mentioned in the judgment/order text.
Time limit for reopening assessments: longer window where escaped income represented as asset triggers extended limitation.
No notice under section 148 may be issued after three years from the end of the relevant assessment year, except that where the Assessing Officer has books, documents or evidence showing escaped income represented as an asset, a longer limitation of up to ten years applies; assets include immovable property, shares and securities, loans and advances, and bank deposits. Transitional protections preserve pre-existing time-barred cases for years beginning on or before 1 April 2021; search-related exceptions for actions on or before 31 March 2021 apply; time allowed for show-cause responses or stays is excluded and, if necessary, the remaining period for the Assessing Officer is extended to seven days.
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