Fixed statutory limitation period overrides extension power, making the assessment time-barred once the special deadline expires.

Section 29(4A), inserted with a non obstante clause, fixed a three-year limitation period for completing the assessment from 20 November 2006 and prevailed over the general extension power under section 29(4). On a plain reading, the Commissioner's extension could not override the special statutory deadline, so the assessment had to be completed within the period expressly prescribed. Because the assessment was made on 26 March 2010, after the outer limit had expired, it was time-barred and the extension had no legal effect.

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Issues: Whether the assessment for assessment year 2005-06 could be completed beyond 20 November 2009 in view of section 29(4A), and whether the Commissioner could extend the limitation period under section 29(4).

Analysis: Section 29(4A) was inserted with a non obstante clause and expressly provided that assessment for the relevant year could be made only within three years from 20 November 2006. The provision was read on its plain language and was held to override section 29(4), including the power to extend time. On that construction, the extension granted for completing the assessment had no legal effect, and the assessment made on 26 March 2010 was beyond the prescribed period.

Conclusion: The assessment was time-barred and the extension could not validate it.

Final Conclusion: The statutory time limit for assessment under the special amendment prevailed over the general extension power, leaving no scope to sustain the impugned assessment.

Ratio Decidendi: Where a later provision prescribing a fixed limitation period contains a non obstante clause, it overrides the earlier extension power and the assessment must be completed within the period expressly prescribed.

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