TMI Blog2014 (2) TMI 183X X X X Extracts X X X X X X X X Extracts X X X X ..... een passed by the Assessing Officer - after a lapse of considerable time, no assessment order can be passed as the proceedings are time barred – as per section 153B proviso 2(a), the limitation for the reassessment is one year, which has already been expired as back as in the year 2003 - now there is no occasion for initiation of the proceedings of reassessment/scrutiny pertinent to the assessee f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nder consideration. During the course of search, certain incriminating documents were found and seized. In these circumstances, the assessee has filed a belated income-tax return on January 8, 1987. The Assessing Officer passed the assessment order dated March 24, 1988, on protective basis without prejudice to the contrary view taken, if any, in the assessment of the other assessees of the group ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issioner of Incometax (Appeals) order and restored it back to the file of the Assessing Officer to pass the assessment order afresh after providing reasonable opportunity to the assessee." With this back ground, learned counsel for the petitioner submits that in pursuance to the direction, the Assessing Officer has not passed any fresh assessment order. In the meantime, the Income-tax record of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ar, which has already been expired as back as in the year 2003. Hence, now there is no occasion for initiation of the proceedings of reassessment/scrutiny pertinent to the assessee for the assessment year 1985-86. In view of the above, we set aside the impugned notice dated August 3, 2011, and direct the opposite parties to give the effect of the Tribunal's order dated June 27, 2002, against whi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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