Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Section 153A creates two separate computational regimes for search-related reassessment: the six-year block uses the expression "immediately preceding" and excludes the search assessment year, while the extended ten-year block is computed "from the end of the assessment year" relevant to the previous year in which search is conducted. That wording requires inclusion of the search assessment year as the first year of the ten-year period. On that basis, Assessment Year 2014-15 fell outside the permissible ten-year limit where the search occurred in Financial Year 2023-24, and the notice under Section 148, with all consequential proceedings, was quashed as time-barred.
Section 153A creates two separate computational regimes for search-related reassessment: the six-year block uses the expression "immediately preceding" and excludes the search assessment year, while the extended ten-year block is computed "from the end of the assessment year" relevant to the previous year in which search is conducted. That wording requires inclusion of the search assessment year as the first year of the ten-year period. On that basis, Assessment Year 2014-15 fell outside the permissible ten-year limit where the search occurred in Financial Year 2023-24, and the notice under Section 148, with all consequential proceedings, was quashed as time-barred.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
