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...
The HC held that Section 153A uses two different computation methods for search assessments. For the six-year block, the phrase "immediately preceding" excludes the search assessment year; for the extended ten-year block in Explanation 1, the period is computed "from the end of" the assessment year relevant to the year of search, so the search assessment year is included as the first year. The Court rejected the Revenue's attempt to apply the six-year exclusion rule to the ten-year period. On that interpretation, Assessment Year 2015-16 was beyond the permissible ten-year span and the notice under Section 148 was quashed as time-barred.
The HC held that Section 153A uses two different computation methods for search assessments. For the six-year block, the phrase "immediately preceding" excludes the search assessment year; for the extended ten-year block in Explanation 1, the period is computed "from the end of" the assessment year relevant to the year of search, so the search assessment year is included as the first year. The Court rejected the Revenue's attempt to apply the six-year exclusion rule to the ten-year period. On that interpretation, Assessment Year 2015-16 was beyond the permissible ten-year span and the notice under Section 148 was quashed as time-barred.
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