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    <title>2025 (12) TMI 1585 - GUJARAT HIGH COURT</title>
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    <description>The dominant issue was whether an assessment made pursuant to search-related proceedings could be sustained as within limitation. The HC held that, after the SC decision dated 06.04.2023, limitation could extend only by sixty days (as only eleven days remained when an interim order had operated), taking the outer date to 05.06.2023; even reckoning from receipt by the AO on 16.04.2023, the assessment dated 30.04.2024 was time-barred. The HC further held that s.153(6)(i) must be read with s.153(1) and cannot be invoked to import a 12-month period into s.153C search assessments, which have distinct, specific limitation. The writ petition was allowed and the assessment was set aside.</description>
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      <title>2025 (12) TMI 1585 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=784045</link>
      <description>The dominant issue was whether an assessment made pursuant to search-related proceedings could be sustained as within limitation. The HC held that, after the SC decision dated 06.04.2023, limitation could extend only by sixty days (as only eleven days remained when an interim order had operated), taking the outer date to 05.06.2023; even reckoning from receipt by the AO on 16.04.2023, the assessment dated 30.04.2024 was time-barred. The HC further held that s.153(6)(i) must be read with s.153(1) and cannot be invoked to import a 12-month period into s.153C search assessments, which have distinct, specific limitation. The writ petition was allowed and the assessment was set aside.</description>
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