Section 153A time bar applied where the assessment year fell beyond the extended 10-year period under the Income-tax Act.

An assessment framed under section 153A for AY 2010-11 was held to be time-barred because the year fell beyond the extended 10-year period in Explanation 1 to section 153A(1) of the Income-tax Act, 1961. The Commissioner (Appeals) had relied on the binding jurisdictional High Court ruling, and in the absence of any contrary judicial precedent or contrary factual material, there was no basis to disturb that finding. The assessment was therefore rightly treated as beyond the permissible period, and the Revenue's challenge failed.

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Issues: Whether the assessment framed under section 153A for Assessment Year 2010-11 was barred as being beyond the extended 10-year period.

Analysis: The assessment year under consideration fell beyond the 10-year period contemplated in Explanation 1 to section 153A(1) of the Income-tax Act, 1961. The order of the Commissioner (Appeals) had followed the binding jurisdictional High Court decision and, in the absence of any contrary judicial precedent or contrary factual material, there was no basis to interfere with that finding.

Conclusion: The assessment was rightly held to be beyond the extended 10-year period and the Revenue's challenge failed.

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