Reassessment Notice for 2013-14 Valid: Issued Before June 30, 2021, u/s 147; Section 149 Proviso Inapplicable.

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....Reopening of assessment u/s 147 - Time limit for notice - since the time period for issuance of reassessment notice for assessment year 2013-14 stood extended until 30th June, 2021 and the income alleged to have escaped assessment is beyond Rs.50 lakhs, the first proviso of Section 149 (as amended by the Finance Act, 2021) is not attracted in the facts of this case and even without the benefit of Instruction No.01/2022 the impugned notice is within limitation. - HC....