Section 147: No Extension for Reopening Income Tax Assessment; Only Unassessed Income Can Be Re-evaluated.

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....Reopening of assessment u/s 147 - third proviso - computation of period of limitation - the said proviso does not in any manner extend the period within which action under Section 147 of the Act can be initiated by the Department. It merely empowers the AO to assess or reassess such income, which is not involved or is the subject matter of any appeal, reference or revision, and has escaped assessment. It does not grant any further extension of time to the Department to initiate a proceeding u/s 147 of the Act. - HC....