2025 (11) TMI 561

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....essee vehemently submitted that 2012-13 cannot be reopened u/s 148 of the Income-tax Act, 1961 [the Act, for short] and is covered by the decision of the Hon'ble Supreme Court in the case of Rajeev Bansal 167 taxmann.com 70. For A.Y 2013-14, the ld. counsel for the assessee submitted that the same is time barred as notice u/s 148 of the Act has been issued after the expiry of the surviving period. The ld. counsel for the assessee further submitted that the ld. CIT(A) has examined the technical issue involved in the case and has given relief to the assessee. 3. The ld. DR, on the other hand, relied on the orders of the authorities below. 4. We have heard the rival submissions and have perused the relevant material on record. The factua....

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....igh Court the computation of 10 assessment years, would be carried out as under. For the sake brevity, it may be reiterated that a notice under section 148 was issued on 30.03.2023 relating to AY 2023-24. This date is material in understanding the time limit for issuance of notice under section 153A that stood prior to amendment in Finance Act,2021. Accordingly, the computation of 10 assessment years, would be computed as under. Alternatively, whether the AO could have issued notice under section 153A of the Act on 30.03.2023 for AY 2012-13. As mentioned above, under section 153A, a notice shall be issued by the AO upto 10 assessment years from the end of the relevant assessment year. Here the relevant assessment year is AY 2023-24. Accordi....