Assessee's appeal allowed, Revenue's appeal dismissed as time-barred; order pronounced on 13 Jan 2022.

The Tribunal allowed the assessee's appeal, quashing the reassessment order as time-barred, and dismissed the Revenue's appeal as infructuous. The order was pronounced in the open court on 13th January 2022.

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Issues Involved:
1. Validity of the assessment order passed under sections 143(3) read with 144A and 147 of the Income Tax Act.
2. Validity of the reassessment proceedings initiated under section 147 of the Income Tax Act.
3. Consideration of alternative claim under section 10A of the Income Tax Act.

Detailed Analysis:

1. Validity of the Assessment Order:
The assessee challenged the assessment order passed under sections 143(3) read with 144A and 147 of the Income Tax Act, arguing that it was invalid under the law. The assessee contended that the original assessment proceedings had already scrutinized the claim under section 10B of the Act, and the reassessment was merely a change of opinion based on a subsequent judicial decision (Regency Creation case). The Tribunal found that the reassessment order dated 30-03-2015, which incorporated directions dated 31-03-2015 from the Additional Commissioner, was pre-dated and thus time-barred. Consequently, the assessment order was set aside as it was passed beyond the permissible time limit.

2. Validity of the Reassessment Proceedings:
The Tribunal examined whether the reassessment proceedings initiated under section 147 were valid. The assessee argued that the reassessment was based on a change of opinion and lacked fresh material. The Revenue contended that the reassessment was justified based on new information from the Regency Creation case, which constituted valid grounds for reopening the assessment. The Tribunal, however, held that the reassessment order was invalid due to the pre-dated nature of the order, rendering the proceedings time-barred.

3. Alternative Claim under Section 10A:
The Revenue's appeal challenged the CIT(A)'s direction to allow the assessee's alternative claim for deduction under section 10A of the Act. Since the Tribunal quashed the assessment order as time-barred, the issues raised in the Revenue's appeal became infructuous and were dismissed.

Conclusion:
The Tribunal allowed the assessee's appeal, quashing the reassessment order as time-barred, and dismissed the Revenue's appeal as infructuous. The order was pronounced in the open court on 13th January 2022.

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