Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
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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.
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