Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
For search-related reassessment, the HC held that the six-year block under section 153A and the extended ten-year block under Explanation 1 use different computation methods, and the language of the ten-year provision requires the search assessment year to be included as the first year in the reckoning. On that construction, a search conducted in FY 2023-24 made AY 2024-25 the first year and AY 2015-16 the tenth year, so AY 2014-15 fell outside the permissible period. The Court followed its earlier view and rejected the Revenue's contrary interpretation, quashing the section 148 notice for AY 2014-15 as time-barred.
For search-related reassessment, the HC held that the six-year block under section 153A and the extended ten-year block under Explanation 1 use different computation methods, and the language of the ten-year provision requires the search assessment year to be included as the first year in the reckoning. On that construction, a search conducted in FY 2023-24 made AY 2024-25 the first year and AY 2015-16 the tenth year, so AY 2014-15 fell outside the permissible period. The Court followed its earlier view and rejected the Revenue's contrary interpretation, quashing the section 148 notice for AY 2014-15 as time-barred.
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