Search-related reassessment limitation turns on including the search assessment year in the ten-year reckoning.

Under the search-related reassessment scheme, the ten-year block is computed from the end of the assessment year relevant to the previous year in which the search is conducted, and the search assessment year is included in that reckoning. The different wording used for the six-year block and the ten-year block was treated as deliberate, requiring different computational methods. Applying that construction, the notice for Assessment Year 2015-16 fell beyond the permissible ten-year 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 2015-16 was barred by limitation because, in computing the ten-year period for search-related reassessment, the assessment year relevant to the previous year in which search was conducted had to be included.

Analysis: The search took place during the financial year 2024-25, making Assessment Year 2025-26 the search assessment year. The statutory scheme under Section 153A distinguishes between the six-year block, described as the six assessment years immediately preceding the search assessment year, and the ten-year block, described in Explanation 1 as the period reckoned from the end of the assessment year relevant to the previous year in which search is conducted. The different phraseology was held to be deliberate and to require different computational methods. On that construction, the search assessment year is included in the ten-year reckoning. The Court also followed its earlier view that the ten-year block under the search provisions must be computed in this manner.

Conclusion: The notice for Assessment Year 2015-16 was held to be beyond the permissible ten-year period and was barred by limitation.

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