Limitation period in search-triggered assessments: ten-year computation includes the search year, rendering the Section 148 notice time-barred.

Interpretation of limitation for search-triggered assessments distinguishes two statutory computation regimes: a six-year block measured by the six assessment years immediately preceding the search assessment year, and a ten-year outer limit measured from the end of the search assessment year which includes the search year as the first year. Applying this differential anchoring, the ten-year computation here excludes the impugned assessment year, producing a time-bar result. Consequently, the Section 148 notice dated 26.03.2025 for the relevant assessment year is held to be barred by limitation and is quashed.

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Issues: (i) Whether the notice issued under Section 148 of the Income-tax Act, 1961 for Assessment Year 2014-15 is barred by limitation.

Analysis: The statutory scheme prescribes two distinct computational regimes for search-triggered assessments: a six-year period described as "six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted" and an extended ten-year period described as "not later than ten assessment years from the end of the assessment year relevant to the previous year in which search is conducted" (Explanation 1 to Section 153A(1)(b)). The differing phraseology is deliberate and requires different anchoring points. The six-year block excludes the search assessment year by virtue of the phrase "immediately preceding", whereas the ten-year block is to be reckoned from the end of the search assessment year and therefore includes the search assessment year as the first year of the ten-year block. Prior authorities applying the same interpretive approach are on point and the ten-year computation that includes the search year results in an outer limit which, in the present facts, excludes the Assessment Year 2014-15 from the permissible ten-year window.

Conclusion: The notice dated 26.03.2025 issued under Section 148 of the Income-tax Act, 1961 for Assessment Year 2014-15 is barred by limitation and is quashed and set aside.

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