Petitioner claimed to have started production of the RMPU’s, in the Selaqui Unit during the financial year 2007-08, and claimed deduction of profits, under S.  80-IC of the Act, in the concerned A.Y. 2008-09. The claim filed by the Petitioner for deduction of profits was selected for scrutiny and rejected by the AO, inter alia, on the ground of violation of the conditions prescribed in S.80-IC(4)(ii) of the Act. Petitioner preferred an appeal before the CIT (A), against the order of the AO and succeeded therein. As a result the deductions claimed by the Petitioner under Section 80-IC of the Act, were allowed. The order of CIT(A), was challenged by the Revenue, before the Income Tax Appellate Tribunal In the meanwhile, Petitioner’s case for AY 2009-10 was also selected for scrutiny on the same ground i.e. deductions claimed under S.80-IC of the Act. Petitioner requested the concerned AO to follow the order of CIT(A), as the same was binding upon him. The concerned AO acceded to Petitioners request and completed the assessment for the AY.2009-10 under S.143(3) of the Act, without disallowing deduction under Section 80-IC of the Act. Subsequently, vide order dated 16.01.2017, ITAT reversed the findings of the CIT(A) w.r.t. AY 2008-09 and allowed departmental appeal in favour of the Revenue. The AO issued the impugned notice dated 25.03.2017, under S. 147/150 of the Act, for reassessment of the return filed by the Petitioner for the AY 2009-10, requiring the Petitioner to file the return for the said AY. Petitioner complied with the notice and sought reasons for re-opening the assessment, which were provided to it by the Revenue. Thereafter, the Petitioner vide letter dated 20.11.2017 raised objections against the reasons provided by the Revenue for reopening the assessment, which were rejected on 07.12.2017, reiterating that reopening of the assessment is necessary and obligatory in consequence of and in order to give effect to, the finding or direction contained in the order dated 16.07.2019  passed by the ITAT.  Dismissing the petition the Court held that the legislature has designedly not placed any time limit under Section 150, and reading a period of limitation into it, would be incorrect approach. In the present case, the date relevant for deciding the question of limitation in terms of Section 150(2), and the observations in Praveen Kumari v. CIT (1999) 237 ITR 339  (SC)  Sharma (KM) v. ITO (2002) 254 ITR 772 (SC) would be the date of the order of the CIT(A), which was passed on 05.10.2011 and was the subject matter of appeal. Thus, the limitation of six years under S.  149, must be alive on the date of passing of the order of CIT (A). In the present case since, as on 05.10.2011, the time limit for reopening of assessment for A.Y. 2009-10 had not lapsed, the order of the ITAT was well within the limitation. Accordingly the reopening of the assessment under S.  147, read with S.  150, was within the period of limitation. (AY. 2009 -10)