https://www.taxtmi.com/caselaws?id=799783 Limitation under Section 153B requires court-ordered stay periods to be excluded during the initial computation under its Explanation, before the resulting composite deadline is tested for eligibility under TOLA. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge limitation and conflict with strict construction of tax limitation provisions. On this approach, the calculated deadlines for stayed years fell outside TOLA's extension window, while assessments for other years were made after the extended deadline. The search assessments, connected notices and penalty orders were therefore time-barred and liable to be quashed. en-us Wed, 23 Sep 2026 00:00:00 +0530 Sat, 26 Sep 2026 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799783 Limitation under Section 153B requires court-ordered stay periods to be excluded during the initial computation under its Explanation, before the resulting composite deadline is tested for eligibility under TOLA. Treating the stay exclusion as an addition after a TOLA extension would improperly enlarge limitation and conflict with strict construction of tax limitation provisions. On this approach, the calculated deadlines for stayed years fell outside TOLA's extension window, while assessments for other years were made after the extended deadline. The search assessments, connected notices and penalty orders were therefore time-barred and liable to be quashed. Case-Laws Income Tax Wed, 23 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799783