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    <title>2025 (6) TMI 574 - DELHI HIGH COURT</title>
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    <description>Delhi HC held that reassessment notices u/s 148A/148 for AY 2014-15 were barred by limitation. The court determined that the ten-year block period under Section 153C read with Section 153A must be calculated from the end of the assessment year pertaining to when the satisfaction note was recorded (AY 2025-26), not from the preceding year. Following the precedent in Ojjus Medicare Pvt. Ltd., the court ruled that since the satisfaction note was recorded in FY 2024-25, the AO could not proceed with assessment for AY 2014-15 as it exceeded the limitation period. The petition was allowed and impugned notices were set aside.</description>
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    <pubDate>Thu, 29 May 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 574 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=772461</link>
      <description>Delhi HC held that reassessment notices u/s 148A/148 for AY 2014-15 were barred by limitation. The court determined that the ten-year block period under Section 153C read with Section 153A must be calculated from the end of the assessment year pertaining to when the satisfaction note was recorded (AY 2025-26), not from the preceding year. Following the precedent in Ojjus Medicare Pvt. Ltd., the court ruled that since the satisfaction note was recorded in FY 2024-25, the AO could not proceed with assessment for AY 2014-15 as it exceeded the limitation period. The petition was allowed and impugned notices were set aside.</description>
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      <pubDate>Thu, 29 May 2025 00:00:00 +0530</pubDate>
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