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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
HC ruled that the Assessing Officer (AO) cannot reopen assessment for AY 2016-17 under Section 153A, as it falls outside the six-year block period following a search action. The notice was invalid because: (1) no asset-related income escape was established, (2) expenses disallowance did not meet statutory criteria for reopening, and (3) the assessment year exceeded the permissible limitation period. The search conducted in FY 2022-23 only allows reassessment for AY 2017-18 through AY 2023-24. Consequently, the HC set aside the impugned notice and terminated the reassessment proceedings.
HC ruled that the Assessing Officer (AO) cannot reopen assessment for AY 2016-17 under Section 153A, as it falls outside the six-year block period following a search action. The notice was invalid because: (1) no asset-related income escape was established, (2) expenses disallowance did not meet statutory criteria for reopening, and (3) the assessment year exceeded the permissible limitation period. The search conducted in FY 2022-23 only allows reassessment for AY 2017-18 through AY 2023-24. Consequently, the HC set aside the impugned notice and terminated the reassessment proceedings.
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