Limitation bar invalidates reassessment notices and orders, requiring their quashing while leaving other contentions open.

Reassessment orders and notices barred by limitation were treated as invalid under a recent binding decision accepted by the parties as governing the limitation issue. The reassessment orders and notices were therefore quashed in favour of the assessees. Other contentions were expressly left open for independent consideration if required in separate proceedings.

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Issues: Whether the reassessment orders and notices were barred by limitation.

Analysis: The parties agreed that the limitation issue was governed by the recent binding decision referred to in the order. The remaining contentions were expressly left open for consideration independently if required in other proceedings.

Conclusion: The reassessment orders and notices were invalid on limitation and were quashed, in favour of the assessees.

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