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    <title>Court Upholds Validity of Tax Reassessment Notices for 2009-2015; 10-Year Limit Applied Due to High Escaped Income.</title>
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    <description>The High Court held that the impugned notices issued for Assessment Years 2009-10 to 2014-15 u/s 153C of the Income Tax Act were valid and not time-barred. The court applied the extended period of 10 years for reassessment proceedings, as the amount of income escaping assessment exceeded Rs. 50 lakh. The 10-year period was computed from the Assessment Year 2018-19, considering the date when the Assessing Officer recorded satisfaction after receiving the seized material on 23.10.2019. The court harmoniously interpreted Sections 153A and 153C, relying on the Supreme Court&#039;s decision in Vikram Sujit Kumar Bhatia, which held the second proviso to Section 153A as clarificatory. Consequently, the notices were upheld as valid within the extended 10-year limitation period.</description>
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    <pubDate>Sat, 07 Dec 2024 08:14:54 +0530</pubDate>
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      <title>Court Upholds Validity of Tax Reassessment Notices for 2009-2015; 10-Year Limit Applied Due to High Escaped Income.</title>
      <link>https://www.taxtmi.com/highlights?id=83774</link>
      <description>The High Court held that the impugned notices issued for Assessment Years 2009-10 to 2014-15 u/s 153C of the Income Tax Act were valid and not time-barred. The court applied the extended period of 10 years for reassessment proceedings, as the amount of income escaping assessment exceeded Rs. 50 lakh. The 10-year period was computed from the Assessment Year 2018-19, considering the date when the Assessing Officer recorded satisfaction after receiving the seized material on 23.10.2019. The court harmoniously interpreted Sections 153A and 153C, relying on the Supreme Court&#039;s decision in Vikram Sujit Kumar Bhatia, which held the second proviso to Section 153A as clarificatory. Consequently, the notices were upheld as valid within the extended 10-year limitation period.</description>
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      <pubDate>Sat, 07 Dec 2024 08:14:54 +0530</pubDate>
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