Dismissing the petition   the Court held that after S.  143(1) acknowledgment, the regular assessment took place under S.  143(3). The scrutiny assessment under S.  143(3) was challenged before the CIT(A)  In the interregnum, i.e., between the acknowledgment under S.  143(1) and passing of the scrutiny assessment under S.  143(3), to protect the interests of the Revenue, the attachment order was passed. Against the final order of assessment under S.  143(3) an appeal was preferred by the assessee before the CIT (A), which was dismissed and, as on date, an appeal was pending before the Appellate Tribunal. In such circumstances, it could not be said that the order had become conclusive. The period of limitation would be reckoned only from the date the order becomes conclusive. The order was not barred by limitation.( AY. 2010-11)