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    <title>2026 (7) TMI 622 - BOMBAY HIGH COURT</title>
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    <description>Limitation for reassessment under Section 147 was governed by Section 153(2) read with Explanation 1 to Section 153, requiring exclusion of time spent on reference to the Valuation Officer under Section 142A. The decisive date was the Assessing Officer&#039;s receipt of the valuation report, not the report date itself; on the admitted facts, the report was received on 25 February 2022 and the sixty-day period expired on 26 April 2022. Although the order bore the date 13 April 2022, it was digitally signed only on 26 May 2022, and the date of preparation was treated as immaterial. The reassessment order was therefore barred by limitation and liable to be quashed.</description>
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      <title>2026 (7) TMI 622 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=794736</link>
      <description>Limitation for reassessment under Section 147 was governed by Section 153(2) read with Explanation 1 to Section 153, requiring exclusion of time spent on reference to the Valuation Officer under Section 142A. The decisive date was the Assessing Officer&#039;s receipt of the valuation report, not the report date itself; on the admitted facts, the report was received on 25 February 2022 and the sixty-day period expired on 26 April 2022. Although the order bore the date 13 April 2022, it was digitally signed only on 26 May 2022, and the date of preparation was treated as immaterial. The reassessment order was therefore barred by limitation and liable to be quashed.</description>
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