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2010 (8) TMI 369 - MADRAS HIGH COURT
Reassessment proceedings - assessee filed return showing "nil" income by claiming deduction under section 80HHC - Assessing Officer reopened the assessment by invoking the provisions under section 147 of the Act - four year period of limitation for invoking the power under section 147 expired on December 31, 2004 - notice for reopening the assessment for the second time was issued to the assessee on August 4, 2005 - proceedings initiated by the Assessing Officer for the second time under section 147 is barred by limitation - proviso to section 147 does not come into play on the facts of the case – Appeal dismissed