Allowing the petition the Court held that no reasonable time was given to the assessee to respond to the final show-cause notice. Since the contention of limitation could be raised at any point of time it could once again be raised by the assessee before the appellate authority and if it was raised that could also be considered as one of the prime objections with regard to the assessment under section 147 read with section 144B.  Matter remanded. (AY.2013-14 to 2015-16)