https://www.taxtmi.com/caselaws?id=770019 The Delhi HC set aside a reassessment notice under Section 148 as barred by limitation. The court held that for Section 153C proceedings, the relevant date for limitation is when the assessing officer decides to initiate reassessment, not when satisfaction is recorded. The block of ten assessment years must be calculated from the end of AY 2025-26, being the assessment year relevant to the financial year when the Section 148 notice was issued. The decision followed earlier HC precedents and the Revenue accepted this position. The petition was allowed and the reassessment notice was quashed. en-us Mon, 28 Apr 2025 00:00:00 +0530 Mon, 05 May 2025 08:37:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770019 The Delhi HC set aside a reassessment notice under Section 148 as barred by limitation. The court held that for Section 153C proceedings, the relevant date for limitation is when the assessing officer decides to initiate reassessment, not when satisfaction is recorded. The block of ten assessment years must be calculated from the end of AY 2025-26, being the assessment year relevant to the financial year when the Section 148 notice was issued. The decision followed earlier HC precedents and the Revenue accepted this position. The petition was allowed and the reassessment notice was quashed. Case-Laws Income Tax Mon, 28 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770019