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        Case ID :
        Income Tax

        The Delhi High Court examined the validity of a reassessment...

        Validity of reassessment u/s 148 challenged - AY 2013-14 beyond block period - Notice quashed.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                The Delhi High Court examined the validity of a reassessment action u/s 148, focusing on the time limit for notice u/s 149 and computation of the "relevant assessment year." It was held that AY 2013-14 fell beyond the ten-year block period. The court emphasized the need to consider the statutory scheme for search assessments pre-Finance Act, 2021, and the date of material transmission to the jurisdictional AO for non-searched entities. The court rejected the reconstruction of the "relevant assessment year" point for non-searched persons and found the notice issued on 30 March 2023 to be beyond limitation, thus quashing it and any consequential actions.
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