Extended 10-Year Reassessment Window Cannot Exclude Search Year: Gujarat HC

Purvibhavin Shah Vs ITO (Gujarat High Court) Section 148 Notice Invalid for AY Beyond 10-Year Limit from Search Year; HC Clarifies 6-Year vs 10-Year Limitation with Mandatory Inclusion of Search Year; Gujarat HC Rejects Revenue’s Method for 10-Year Limitation Calculation; Validity of Notice u/s 148 for AY 2014–15 Held Barred by Limitation in Search-Related Reassessment. The Gujarat High Court examined whether a notice issued under Section 148 of the Income Tax Act for Assessment Year (AY) 2014–15, pursuant to a search conducted on 08.02.2024, was barred by limitation. The core issue was ...