https://www.taxtmi.com/caselaws?id=770707 The Delhi HC set aside a notice under Section 148 as barred by limitation in reopening proceedings. The court held that for limitation purposes under Section 153C, the relevant date is when the Assessing Officer decides to initiate re-assessment proceedings, not when satisfaction is recorded regarding assets found during search. The ten-year block period must be calculated from the end of AY 2024-25, being the assessment year relevant to the financial year when the impugned notice was issued on 30.03.2024. The decision followed earlier HC precedents in similar cases. en-us Fri, 02 May 2025 00:00:00 +0530 Thu, 15 May 2025 07:32:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770707 The Delhi HC set aside a notice under Section 148 as barred by limitation in reopening proceedings. The court held that for limitation purposes under Section 153C, the relevant date is when the Assessing Officer decides to initiate re-assessment proceedings, not when satisfaction is recorded regarding assets found during search. The ten-year block period must be calculated from the end of AY 2024-25, being the assessment year relevant to the financial year when the impugned notice was issued on 30.03.2024. The decision followed earlier HC precedents in similar cases. Case-Laws Income Tax Fri, 02 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770707