Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
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The text clarifies computation of limitation for reassessment following a search: the statutory language creates two distinct periods - a six-assessment-year window that excludes the assessment year corresponding to the previous year of the search, and a separate ten-assessment-year outer limit that is reckoned from the end of the search assessment year and therefore includes that year as the first of the ten. Applying this construction, the ten-year outer limit can render reopening for a specified assessment year time-barred; accordingly, notices issued beyond that ten-year block were held invalid in the described instance.
The text clarifies computation of limitation for reassessment following a search: the statutory language creates two distinct periods - a six-assessment-year window that excludes the assessment year corresponding to the previous year of the search, and a separate ten-assessment-year outer limit that is reckoned from the end of the search assessment year and therefore includes that year as the first of the ten. Applying this construction, the ten-year outer limit can render reopening for a specified assessment year time-barred; accordingly, notices issued beyond that ten-year block were held invalid in the described instance.
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