The Assessing Officer failed to complete reassessment proceedings initiated pursuant to a notice issued under section 148 within the statutory period of nine months prescribed under the second proviso to section 153(2). The High Court held that, after expiry of the statutory period, the Assessing Officer could not issue a fresh notice under section 148 for the same assessment year merely because the earlier reassessment proceedings had not been completed. Such a course would defeat the statutory scheme providing finality and certainty to the assessee. Accordingly, the second notice was quashed, and the assessment was held to have attained finality upon expiry of the statutory time-limit. (AY. 2003-04)