Admissibility of inquiry statements: such statements require formal examination and admission before the adjudicating authority, or they are inadmissi...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
