https://www.taxtmi.com/caselaws?id=778397 ITAT, AT allowed the Rule 27 plea and held AY 2008-09 was outside the permissible limitation block. Counting six prescribed years and the expanded "for the relevant assessment year or years" ten-year span up to AY 2018-19 excluded AY 2008-09, so the assessment under s.153A for that year was quashed following the stricter interpretation in light of the SC decision in Dilip Kumar. The Tribunal limited relief under Rule 27 to upholding the lower appellate order and otherwise upheld the CIT(A)'s findings. en-us Thu, 16 Jan 2025 00:00:00 +0530 Tue, 16 Sep 2025 09:02:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778397 ITAT, AT allowed the Rule 27 plea and held AY 2008-09 was outside the permissible limitation block. Counting six prescribed years and the expanded "for the relevant assessment year or years" ten-year span up to AY 2018-19 excluded AY 2008-09, so the assessment under s.153A for that year was quashed following the stricter interpretation in light of the SC decision in Dilip Kumar. The Tribunal limited relief under Rule 27 to upholding the lower appellate order and otherwise upheld the CIT(A)'s findings. Case-Laws Income Tax Thu, 16 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778397