Assessee-company was engaged in business of development and export of software. Assessing Officer passed in name of a company that existed prior to merger with assessee. Tribunal quashed order reserving liberty to revenue to take action in accordance with law. Pursuant to said order, a notice was issued under section 148 read with section 150 proposing to reopen assessment of assessee for assessment year 2008-09 in year 2019. Assessee objected to same on ground that notice was issued 10 years after assessment. On writ the Court held that Tribunal set aside assessment order on ground that assessment order was passed in name of merged company and not in name of assessee and he did not give any finding or direction for reopening assessment. Section 150 enables revenue to reopen an assessment pursuant to an order in appeal, but on twin conditions, i.e., to give effect to any finding or direction. Notice under section 148 could not be saved by addition of section 150 as it did not satisfy two conditions with regard to findings in furtherance of order in appeal and direction as contained in section 150 and, thus, reopening of assessment was barred by time limit prescribed under section 149(1)(a) or (b) of the Act.  (AY. 2008-09)