Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
