https://www.taxtmi.com/caselaws?id=783205 HC held that the second reopening notice dated 03.10.2008 for AY 2003-04 was wholly without jurisdiction and barred by limitation under Section 153(2). Once the first reopening notice was issued on 28.03.2007, the reassessment had to be completed by 31.12.2007, as mandated by the second proviso to Section 153(2). The AO failed to complete the reassessment within this period despite having full opportunity. The statute does not permit a fresh or second reopening to cure such failure. Exercising writ jurisdiction, HC quashed the second notice and all consequential proceedings, declaring that the assessment for AY 2003-04 stood final upon expiry of the statutory deadline. en-us Thu, 27 Nov 2025 00:00:00 +0530 Thu, 11 Dec 2025 08:55:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783205 HC held that the second reopening notice dated 03.10.2008 for AY 2003-04 was wholly without jurisdiction and barred by limitation under Section 153(2). Once the first reopening notice was issued on 28.03.2007, the reassessment had to be completed by 31.12.2007, as mandated by the second proviso to Section 153(2). The AO failed to complete the reassessment within this period despite having full opportunity. The statute does not permit a fresh or second reopening to cure such failure. Exercising writ jurisdiction, HC quashed the second notice and all consequential proceedings, declaring that the assessment for AY 2003-04 stood final upon expiry of the statutory deadline. Case-Laws Income Tax Thu, 27 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783205