Assessment Reopening for LLP Conversion: Only Year of Succession and Prior Year Assessable u/s 170(2).

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....Reopening of assessment u/s 147 - Conversion of company into LLP - notice in hands of Successor company, i.e. in the hands of assessee LLP - On carefully considering the provisions of section 170(2), years which can be assessed for the income of the predecessor can be the year of succession (upto the date of succession) and the immediately preceding previous year and no other years can be assessed in the hands of the successor. - AT....