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High Court Invalidates Reassessment u/s 153C Due to Expired Limitation Period in Section 153(2.

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....Reopening of assessment post annulling proceeding u/s 153C - The proceeding for re assessment were completed beyond the period of limitation as prescribed under Section 153(2) of the Act. Admittedly, the first notice which was served on the business premises of the assessee was existing and was not withdrawn. Therefore, the same continued to subsist and the finding of the tribunal that Assessing Officer could issue two notices is perverse. - HC....