Search-based reassessment limitation turns on distinct six-year and ten-year computation formulas; notice was time-barred.

For search-based reassessment, the six-year period under Section 153A(1)(b) and the extended ten-year period under Explanation 1 to Section 153A are computed by different statutory formulas. The ten-year reckoning runs from the end of the assessment year relevant to the previous year in which the search is conducted, so the search assessment year is included in that count. On that construction, Assessment Year 2014-15 fell outside the permissible ten-year period, making the Section 148 notice time-barred and liable to be quashed.

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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.

Analysis: The search took place on 08.02.2024 during Financial Year 2023-24, and the controversy turned on the computation of the ten-year block for proceedings arising from search. The Court held that Section 153A(1)(b) uses one formula for six assessment years immediately preceding the search assessment year, while Explanation 1 to Section 153A uses a different formula for the extended ten-year period by reckoning from the end of the assessment year relevant to the previous year in which search is conducted. On that construction, the search assessment year is included in the ten-year count. Applying that statutory scheme, Assessment Year 2014-15 fell beyond the permissible ten-year period.

Conclusion: The notice under Section 148 for Assessment Year 2014-15 was time-barred and liable to be quashed.

Final Conclusion: The writ petition succeeded and the reopening notice was set aside on limitation grounds.

Ratio Decidendi: For search-based reassessment, the six-year and ten-year periods are computed by distinct statutory formulas, and the assessment year relevant to the previous year of search is included in the ten-year reckoning under Explanation 1 to Section 153A.

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