https://www.taxtmi.com/caselaws?id=796953 For search-based reassessment where the search falls within Section 152(3), the pre-Finance (No. 2) Act, 2024 regime applies. The first proviso to Section 149(1) adopts the limitation framework of Sections 153A and 153C for assessment years beginning on or before 1 April 2021. Under Explanation 1 to Section 153A, the ten-year period runs from the end of the assessment year relevant to the financial year of search. For a search in financial year 2024-25, the permissible ten-year block extends from AY 2016-17 to AY 2025-26; AY 2015-16 falls outside it. A reassessment notice for AY 2015-16 is therefore beyond limitation and without jurisdiction. en-us Tue, 20 Jan 2026 00:00:00 +0530 Thu, 13 Aug 2026 08:30:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796953 For search-based reassessment where the search falls within Section 152(3), the pre-Finance (No. 2) Act, 2024 regime applies. The first proviso to Section 149(1) adopts the limitation framework of Sections 153A and 153C for assessment years beginning on or before 1 April 2021. Under Explanation 1 to Section 153A, the ten-year period runs from the end of the assessment year relevant to the financial year of search. For a search in financial year 2024-25, the permissible ten-year block extends from AY 2016-17 to AY 2025-26; AY 2015-16 falls outside it. A reassessment notice for AY 2015-16 is therefore beyond limitation and without jurisdiction. Case-Laws Income Tax Tue, 20 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796953