Reassessment Proceedings u/s 147 Dismissed for Being Time-Barred; Department Fails to Prove Compliance with Proviso Conditions.

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....Reopening of assessment u/s 147 - whether Assessment barred by limitation? - Since the burden of establishing the satisfaction of the statutory condition set out in the proviso rests fully upon the Department, and such burden has not been discharged in the present case, the impugned proceedings for reassessment fail. - HC....