Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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Statute prescribes distinct computation for the six-year and ten-year limitation periods for reopening assessments under the search provisions; the six-year window is counted from the preceding year while the ten-year period is reckoned from the end of the assessment year relating to the previous year in which the search occurred, and therefore the ten-year span runs later than the six-year span. Applying that computation to a search dated 09.05.2024 yields AY 2025-26 as the first year and AY 2016-17 as the tenth year, rendering AY 2015-16 beyond the ten-year period and the notice to reopen that year untenable and quashed.
Statute prescribes distinct computation for the six-year and ten-year limitation periods for reopening assessments under the search provisions; the six-year window is counted from the preceding year while the ten-year period is reckoned from the end of the assessment year relating to the previous year in which the search occurred, and therefore the ten-year span runs later than the six-year span. Applying that computation to a search dated 09.05.2024 yields AY 2025-26 as the first year and AY 2016-17 as the tenth year, rendering AY 2015-16 beyond the ten-year period and the notice to reopen that year untenable and quashed.
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