Extended ten-year search limitation includes the search year, rendering the reassessment notice time-barred.

The extended ten-year limitation under the search-assessment framework was construed by giving full effect to the statutory formula in Explanation 1 to section 153A. The court treated the assessment year relevant to the previous year in which the search was conducted as part of the reckoning, because the provision uses a different computation from the six-year block and that distinction is deliberate. Applying that method, the notice under section 148 for Assessment Year 2014-15 fell outside the permissible period and was barred by limitation.

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Issues: Whether the notice issued under section 148 of the Income-tax Act, 1961 for Assessment Year 2014-15 was barred by limitation in the context of a search conducted on 08.02.2024 and the computation of the ten-year block under the search-assessment scheme.

Analysis: The search took place during Financial Year 2023-24, so the assessment year relevant to the previous year of search had to be identified first for applying the statutory time limits. The language of section 153A(1)(b) provides a six-year block by using the phrase "immediately preceding", while Explanation 1 to section 153A employs a different formula, namely "from the end of the assessment year relevant to the previous year in which search is conducted". That distinction was treated as deliberate and mandatory, requiring the search assessment year to be counted in the ten-year block. The same computational principle was held to govern the extended limitation framework, and the Court followed the earlier view that the search year is included while computing the ten-year period.

Conclusion: The notice under section 148 for Assessment Year 2014-15 was beyond the permissible ten-year period and was barred by limitation.

Ratio Decidendi: For computing the extended ten-year period under Explanation 1 to section 153A, the assessment year relevant to the previous year in which search is conducted must be included in the reckoning, because the statute uses a different formula from the six-year block and that language must be given full effect.

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