Broker trading-system "technical glitch" redefinition and narrowed incident-reporting regime for large IBT/STWT brokers requiring 2-hr notice and 14-w...
Computation of limitation for reopening after a search must treat the six-year block and the ten-year outer limit differently: the six-year period is computed with reference to the assessment year relevant to the previous year in which the search occurred, while the ten-year outer limit is reckoned backwards from the end of that assessment year. Applying this method to a search on 04.03.2022 places AY 2013-14 as the tenth year and excludes AY 2012-13; consequently a notice issued under the reopening provision for AY 2012-13 was held time-barred and quashed.
Computation of limitation for reopening after a search must treat the six-year block and the ten-year outer limit differently: the six-year period is computed with reference to the assessment year relevant to the previous year in which the search occurred, while the ten-year outer limit is reckoned backwards from the end of that assessment year. Applying this method to a search on 04.03.2022 places AY 2013-14 as the tenth year and excludes AY 2012-13; consequently a notice issued under the reopening provision for AY 2012-13 was held time-barred and quashed.
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