https://www.taxtmi.com/caselaws?id=472867 Under section 153A, the six assessment years are those immediately preceding the assessment year relevant to the previous year of search, excluding the search assessment year. In contrast, Explanation 1 to section 153A, applied pari materia to section 153C and the limitation framework under section 149, calculates the ten-year period from the end of the assessment year relevant to the search year. The search assessment year therefore forms the first year of that ten-year block. For a search during FY 2024-25, AY 2015-16 falls outside the prescribed period, making a section 148 notice time-barred. en-us Wed, 08 Apr 2026 00:00:00 +0530 Tue, 27 Oct 2026 13:46:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472867 Under section 153A, the six assessment years are those immediately preceding the assessment year relevant to the previous year of search, excluding the search assessment year. In contrast, Explanation 1 to section 153A, applied pari materia to section 153C and the limitation framework under section 149, calculates the ten-year period from the end of the assessment year relevant to the search year. The search assessment year therefore forms the first year of that ten-year block. For a search during FY 2024-25, AY 2015-16 falls outside the prescribed period, making a section 148 notice time-barred. Case-Laws Income Tax Wed, 08 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472867