Limitation for notices under Sections 153A and 153C is reckoned backward from the assessment year in which the satisfaction note is recorded. Where the note was recorded in AY 2024-25, the stated extended limitation reached only AY 2015-16. A notice for AY 2010-11 therefore fell outside the permissible period and was quashed as time-barred.
Limitation for notices under Sections 153A and 153C is reckoned backward from the assessment year in which the satisfaction note is recorded. Where the note was recorded in AY 2024-25, the stated extended limitation reached only AY 2015-16. A notice for AY 2010-11 therefore fell outside the permissible period and was quashed as time-barred.
Note: It is a system-generated summary and is for quick reference only.