Income Tax Assessment Reopening: Notice Invalid After Limitation Period Expired, Despite Finance Act 2012 Extension.

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....Reopening of assessment u/s 147 - period of limitation extended to 16 years vide Finance Act, 2012- validity of notice for the period which has been expired already income escaped pertained to assets located outside India - the notice under Section 148 in the present case was issued on 27.03.2015; therefore, as per the facts of the present case also when the amendment extending limitation for issuing notice under Section 148 of the Act was brought on the Statute, the limitation for issuing notice in the present case already stood expired. - AT....