https://www.taxtmi.com/caselaws?id=789421 For search-based reassessment, the six-year period under Section 153A(1)(b) and the extended ten-year period under Explanation 1 to Section 153A are computed by different statutory formulas. The ten-year reckoning runs from the end of the assessment year relevant to the previous year in which the search is conducted, so the search assessment year is included in that count. On that construction, Assessment Year 2014-15 fell outside the permissible ten-year period, making the Section 148 notice time-barred and liable to be quashed. en-us Fri, 20 Mar 2026 00:00:00 +0530 Tue, 07 Apr 2026 11:19:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789421 For search-based reassessment, the six-year period under Section 153A(1)(b) and the extended ten-year period under Explanation 1 to Section 153A are computed by different statutory formulas. The ten-year reckoning runs from the end of the assessment year relevant to the previous year in which the search is conducted, so the search assessment year is included in that count. On that construction, Assessment Year 2014-15 fell outside the permissible ten-year period, making the Section 148 notice time-barred and liable to be quashed. Case-Laws Income Tax Fri, 20 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789421