Search reassessment limitation: ten-year block includes the search year, making the notice for Assessment Year 2015-16 time-barred.

The reassessment notice for Assessment Year 2015-16 was held time-barred because the ten-year search-related block is computed from the end of the relevant assessment year, which includes the search assessment year in the reckoning. The Court distinguished this from the "six assessment years immediately preceding" formula, which excludes the search assessment year. Applying that interpretation, Assessment Year 2015-16 fell outside the permissible ten-year period and the notice under section 148 was without jurisdiction.

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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, and whether the ten-year block under the search-related reassessment scheme includes the search assessment year in its computation.

Analysis: The Court held that the statutory language governing six assessment years and the extended ten-year period employs different computational formulas. The phrase "six assessment years immediately preceding" excludes the search assessment year, whereas the expression "not later than ten assessment years from the end of the assessment year" requires reckoning from the end of that assessment year and therefore includes the search assessment year in the ten-year block. Applying that interpretation to the facts, the search year was Assessment Year 2025-26 and Assessment Year 2015-16 fell beyond the permissible ten-year limit.

Conclusion: The notice under section 148 for Assessment Year 2015-16 was held to be time-barred and without jurisdiction.

Ratio Decidendi: Where the statute prescribes a ten-year block to be computed "from the end of" the assessment year relevant to the search, the search assessment year is included in the reckoning, unlike the six-year block which is computed by excluding that year.

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