The assessee had challenged the reassessment notice issued u/s 148 dated 20th March, 2019 for AY 2013-14, in the backdrop of pending proceedings before the Settlement Commission u/s 245C. The High Court had granted an interim stay on 20th Dec., 2019 restraining the AO from continuing reassessment proceedings. Subsequently, the writ petition was dismissed as withdrawn on 13th Dec., 2023, thereby vacating the stay. The Revenue contended that the limitation stood extended u/s 153(6) on account of Court proceedings. The High Court held that s. 153(6) had no application since there was neither any “finding” nor any “direction” issued by the Court requiring completion of assessment. Instead, the proviso to Explanation 1 to s. 153 applied, since the reassessment was otherwise required to be completed by 31st Dec., 2019 and the remaining time available was less than sixty days. Therefore, the AO was mandatorily required to complete the reassessment within sixty days from the date the stay was vacated, i.e., by 11th Feb., 2024. As the reassessment proceedings continued beyond this period, they were held to be barred by limitation and were accordingly quashed. (AY. 2013-14)