Co-operative credit society deduction on bank deposit interest upheld where funds were business funds and income remained attributable to member credi...
Taking the date of the search as 23.11.2021 in Financial Year 2021-22, the court treated Assessment Year 2022-23 as the first assessment year and Assessment Year 2013-14 as the tenth; therefore Assessment Year 2012-13 falls beyond the ten-year limitation and the reassessment notice under Section 148 is time-barred and set aside. An alternative contention that the proviso to Section 149 resets limitation for notices arising from post-search knowledge was noted but not accepted or addressed on its merits by the court. Decision favours the assessee; notice quashed as barred by limitation.
Taking the date of the search as 23.11.2021 in Financial Year 2021-22, the court treated Assessment Year 2022-23 as the first assessment year and Assessment Year 2013-14 as the tenth; therefore Assessment Year 2012-13 falls beyond the ten-year limitation and the reassessment notice under Section 148 is time-barred and set aside. An alternative contention that the proviso to Section 149 resets limitation for notices arising from post-search knowledge was noted but not accepted or addressed on its merits by the court. Decision favours the assessee; notice quashed as barred by limitation.
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