https://www.taxtmi.com/highlights?id=96726 Taking the date of the search as 23.11.2021 in Financial Year 2021-22, the court treated Assessment Year 2022-23 as the first assessment year and Assessment Year 2013-14 as the tenth; therefore Assessment Year 2012-13 falls beyond the ten-year limitation and the reassessment notice under Section 148 is time-barred and set aside. An alternative contention that the proviso to Section 149 resets limitation for notices arising from post-search knowledge was noted but not accepted or addressed on its merits by the court. Decision favours the assessee; notice quashed as barred by limitation. en-us Mon, 09 Feb 2026 10:06:25 +0530 Mon, 09 Feb 2026 10:06:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96726 Taking the date of the search as 23.11.2021 in Financial Year 2021-22, the court treated Assessment Year 2022-23 as the first assessment year and Assessment Year 2013-14 as the tenth; therefore Assessment Year 2012-13 falls beyond the ten-year limitation and the reassessment notice under Section 148 is time-barred and set aside. An alternative contention that the proviso to Section 149 resets limitation for notices arising from post-search knowledge was noted but not accepted or addressed on its merits by the court. Decision favours the assessee; notice quashed as barred by limitation. Highlights Income Tax Mon, 09 Feb 2026 10:06:25 +0530 https://www.taxtmi.com/highlights?id=96726