Held that in  PCIT v. Abhisar Buildwell P. Ltd (2023) 454 ITR 212 (SC)   the  liberty which the Supreme Court accorded and the limited right inhering in the Revenue to initiate reassessment proceedings under section 147 was subject to that power being otherwise compliant with the Chapter pertaining to reassessment as contained in the Act. The observations of the Supreme Court could not be read or construed as a carte blanche enabling the Revenue to overcome and override the restrictions stipulated in section 149. The observations of the Supreme Court intended to merely convey that the annulment of the search assessments would not deprive or denude the Revenue of its power to reassess and which independently existed. The Supreme Court being mindful of the statutory prescriptions, which otherwise imbued the commencement of reassessment, qualified that observation by providing that such an action would have to be in accordance with law. This note of caution appeared at various places in that judgment and was apparent from the observation that the power to reassess would be subject to the fulfilment of the conditions mentioned in sections 147 and 148. while according liberty to the Revenue to initiate reassessment, the Supreme Court pertinently observed that it would be subject to the proposed action being in accordance with law and if “permissible in law”. Therefore, neither of these decisions could be read as enabling the Revenue to overcome the statutory bar of limitation. Those judgments could not be construed to be giving liberty to the Revenue from the obligation of independently establishing that the proposed action for reassessment under section 147 would otherwise be in accordance with law. That the expression “finding” as occurring in section 150 should be understood to be a conclusion or a decision of an authority or Tribunal rendered in the context of a particular case and essential for determining the grant of relief. A “direction”, would constitute one which an authority was empowered to issue under the Act. Tested on those precepts, the observations in PR. CIT v. Abhisar Buildwell P. Ltd(20223) 454 ITR 212 (SC)  as amounting to a finding since the principal question in those appeals was with respect to the validity of the search assessments which were undertaken could not be countenanced. The Supreme Court had, in order to balance equities, had additionally observed that it would be open for the Revenue to commence reassessment, if otherwise permissible in law and such observation could not be viewed as amounting to a direction which would enable the Revenue to overcome the prescription of limitation which otherwise applied. Accordingly the  reassessment notice under section 148 and the consequential proceedings under section 147 were quashed.   (AY.2007-08 to 2012-13)