Human-probability test defeats political donation deductions where banking records mask accommodation-entry fund layering rather than genuine contribu...
Reassessment limitation for assessment years commencing on or before 1 April 2021 remains governed by the first proviso to Section 149(1), which preserves the pre-amendment limitation. A post-amendment search cannot by itself invoke the substituted ten-year period. The six-year period under Section 153A covers years immediately preceding the search assessment year, while the ten-year period under Explanation 1 runs from the end of, and includes, the search assessment year. On that computation, A.Y. 2012-13 lay outside both periods, rendering the reassessment notice and consequential proceedings time-barred and quashed.
Reassessment limitation for assessment years commencing on or before 1 April 2021 remains governed by the first proviso to Section 149(1), which preserves the pre-amendment limitation. A post-amendment search cannot by itself invoke the substituted ten-year period. The six-year period under Section 153A covers years immediately preceding the search assessment year, while the ten-year period under Explanation 1 runs from the end of, and includes, the search assessment year. On that computation, A.Y. 2012-13 lay outside both periods, rendering the reassessment notice and consequential proceedings time-barred and quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
