https://www.taxtmi.com/caselaws?id=783623 Where a valid search u/s 132 is conducted on the assessee, the special assessment regime u/s 153A-153D overrides the general reassessment power u/s 147; the plea that the search was on "another person" was rejected as contrary to the panchnama, and the assessee was held to be a searched person. Although the year of search (AY 2018-19) is not within the six preceding years referred to in s.153A, the limitation in s.153B(1) expressly governs both the six years and the relevant year of search; therefore, the statutory outer time limit (ending 31.12.2019) was mandatory. The assessment framed on 25.03.2023 was held time-barred and void ab initio and was quashed. en-us Mon, 08 Dec 2025 00:00:00 +0530 Fri, 19 Dec 2025 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783623 Where a valid search u/s 132 is conducted on the assessee, the special assessment regime u/s 153A-153D overrides the general reassessment power u/s 147; the plea that the search was on "another person" was rejected as contrary to the panchnama, and the assessee was held to be a searched person. Although the year of search (AY 2018-19) is not within the six preceding years referred to in s.153A, the limitation in s.153B(1) expressly governs both the six years and the relevant year of search; therefore, the statutory outer time limit (ending 31.12.2019) was mandatory. The assessment framed on 25.03.2023 was held time-barred and void ab initio and was quashed. Case-Laws Income Tax Mon, 08 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783623