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    <title>Six-year limitation under Section 201(1) governs time bar; only assessment within six years upheld, others quashed</title>
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    <description>The HC ruled that for Section 201(1) proceedings the statutory six-year period (adopted as the reasonable yardstick) governs the limitation inquiry, rejecting a blanket seven-year or one-size-fits-all approach and criticizing Revenue delay. Applying the six-year reckoning, the order for AY 2010-11 was set aside as time-barred; the order for AY 2011-12 was held valid as within the limitation period; orders for the remaining assessment years (subsequent four years) were set aside for being passed beyond six years. The court therefore quashed time-barred Section 201 orders and upheld only the order falling within the six-year limitation.</description>
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    <pubDate>Fri, 05 Sep 2025 08:10:37 +0530</pubDate>
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      <title>Six-year limitation under Section 201(1) governs time bar; only assessment within six years upheld, others quashed</title>
      <link>https://www.taxtmi.com/highlights?id=92248</link>
      <description>The HC ruled that for Section 201(1) proceedings the statutory six-year period (adopted as the reasonable yardstick) governs the limitation inquiry, rejecting a blanket seven-year or one-size-fits-all approach and criticizing Revenue delay. Applying the six-year reckoning, the order for AY 2010-11 was set aside as time-barred; the order for AY 2011-12 was held valid as within the limitation period; orders for the remaining assessment years (subsequent four years) were set aside for being passed beyond six years. The court therefore quashed time-barred Section 201 orders and upheld only the order falling within the six-year limitation.</description>
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      <pubDate>Fri, 05 Sep 2025 08:10:37 +0530</pubDate>
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