Reopening of 2002-03 and 2003-04 assessments u/s 147 invalid due to expired limitation period.

Validity of reopening of assessment u/s 147 - by the time, assessment order for the assessment year 2004-05 was passed on 31.12.2010, six year period for reopening of assessment for the assessment years 2002-03 & 2003-04 was expired on 31.03.2009 & 31.03.2010 and thus, we are of the considered view that reopening of assessment in terms of section 150(1) of the Act, is clearly barred by limitation, because of exception provided u/s. 150(2) of the Income Tax Act, 1961, and thus, notice issued u/s. 148 and consequent assessment order passed u/s. 143(3) r.w.s. 147 for the assessment years 2002-03 & 2003-04 is barred by limitation. - AT .....

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