Assessee’s writ petition challenging reopening was disposed of by the High Court with directions to the AO to furnish reasons, allow objections, and pass an order.AO then proceeded with reassessment. Assessee contended that outer time limit under Section 153(2) expired on 19-02-2024, and no order was passed by then. Revenue argued that the extended period under Section 153(6)(i) applied, as reassessment was in consequence of the High Court’s order Court held that the extended period under Section 153(6)(i) applies only if the principal order contains a ‘finding or direction’. Since the High Court’s order merely laid down timelines for furnishing reasons and disposing of objections, it did not constitute a ‘finding or direction’ under section 153(6)(i). Applying section 153(2), first proviso, read with the first proviso to Explanation 1 to section 153, reassessment was barred by limitation. (AY. 2015-16)
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