Limitation under income-tax law turns on receipt of Section 144B directions, not their issuance, for exclusion under Section 153.

For limitation under Section 153 of the Income-tax Act, 1961, the relevant date for exclusion under Explanation 1(iv) is the date the Income-tax Officer receives the Inspecting Assistant Commissioner's directions under Section 144B, not the date those directions are issued. Applying that interpretation, the assessment order passed after receipt of the directions was held to be within time, and the limitation question was answered against the assessee.

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Issues: Whether, for the purpose of limitation under Section 153 of the Income-tax Act, 1961, the relevant date is the date on which the Income-tax Officer received the directions of the Inspecting Assistant Commissioner under Section 144B or the date on which the directions were issued.

Analysis: The assessment year was governed by the limitation scheme in Section 153(1)(a)(iii) read with Explanation 1(iv) to Section 153 of the Income-tax Act, 1961. On the admitted facts, the Income-tax Officer received the directions on 5 September 1979 and passed the assessment order on 21 September 1979. The wording of Explanation 1(iv) made the receipt of directions by the Income-tax Officer the relevant date for exclusion in computing limitation, not the date of issuance of the directions by the Inspecting Assistant Commissioner.

Conclusion: The assessment order was within limitation, and the question was answered in the affirmative against the assessee.

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