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The HC held that the period of limitation for reopening assessments under Section 153C read with Section 153A must be calculated from the end of the assessment year relevant to the financial year in which the reopening action was initiated (i.e., when the Section 148 notice was issued). Since the assessment year in question (AY 2014-15) fell beyond the ten-year limitation period contemplated in these provisions, the Court allowed the petition and set aside the impugned notice as time-barred. This ruling clarifies how the block period for reopening assessments should be determined when applying limitation provisions.
The HC held that the period of limitation for reopening assessments under Section 153C read with Section 153A must be calculated from the end of the assessment year relevant to the financial year in which the reopening action was initiated (i.e., when the Section 148 notice was issued). Since the assessment year in question (AY 2014-15) fell beyond the ten-year limitation period contemplated in these provisions, the Court allowed the petition and set aside the impugned notice as time-barred. This ruling clarifies how the block period for reopening assessments should be determined when applying limitation provisions.
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