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2020 (4) TMI 810 - HC - Income TaxReopening the Assessment u/s 147 - period of limitation - limitation under sub-Section 2 to Section 150 - whether the reopening of the assessment for the three Assessment Years would get time-barred in view of the order of the Income Tax Appellate Tribunal - Computation of deduction u/s 10B - HELD THAT:- Limitation under sub-Section 2 to Section 150 will apply only when the limitation had already expired by the time before the assessment order for the Assessment Year 2006-07 was made. If not, there is a saving of limitation u/s 150(1) - It is for this reason, the Income Tax Appellate Tribunal [2015 (8) TMI 1500 - ITAT CHENNAI] held that such recomputation will be subject to limitation. No merits in the present Writ Petitions. The petitioner is directed to participate in the proceedings before the respondent. Since the dispute pertains to the AY 2003-04 to 2005-06, the petitioner is directed to file objections/ representations, if any, within a period of thirty days from the date of receipt of a copy of this order.
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