Reopening assessments based on documents found during a search...

Reopening assessments based on documents found during a search must respect the ten-year limitation applicable to reassessments under the tax statute; the High Court found that treating the search date and subsequent assessment year calculation rendered the impugned reopening for the earlier assessment year beyond the permissible ten years and therefore invalid, and quashed the reopening for that year. The Court held that the limitation point is a pure question of statutory interpretation that may be raised at any stage and exercised its writ jurisdiction to set aside the reassessment initiated in breach of the limitation rule.