On writ the  assessee challenged the order as barred by limitation. Allowing the petition the Court held that for the assessment year 2014-15, the date of Tribunal’s order under section 254 was October 4, 2019 when it was remanded to the Assessing Officer for de novo consideration. Accordingly the due date under section 153(3) read with the proviso thereto to pass fresh order pursuant to the Tribunal’s order expired on March 31, 2021, i. e., 12 months from the end of the financial year in which the order was received by the specified authority. In view of Notification No. 10 of 2021 dated February 27, 2021 ([2021] 432 ITR (St.) 14) issued by the Central Board of Direct Taxes in the exercise of the powers conferred by sub-section (1) of section 3 of the notification under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 and in partial modification of the earlier notification, the time to pass the assessment order was extended to September 30, 2021. The date on which the draft assessment order had been passed was September 28, 2021. Therefore, there was no possibility of passing any final assessment order as the matter had got time barred on September 30, 2021. Since the final assessment order had not been passed before this date the proceedings were barred by limitation. Therefore, the return as filed by the assessee should be accepted. Since the order had been passed by the Tribunal on October 4, 2019, the time would be twelve months from the end of the financial year in which the order under section 254 was received. The submission of the Department that when there was a remand the Assessing Officer was unfettered by limitation would run counter to the avowed object of provisions that were considered while framing the provisions of section 144C. The assessment should have been concluded within twelve months as provided in section 153(3) when there had been remand to the Assessing Officer by the Tribunal’s order under section 254. Within this twelve months prescribed, the Assessing Officer was to ensure that the entire procedure prescribed under section 144C was completed. Since no final assessment order could be passed as it was time barred, the return of income as filed by assessee was to be accepted. This would however, not preclude the Department from taking any other steps in accordance with law. For the  assessment year 2018-19 is concerned since the original assessment order was in question the period of limitation prescribed under section 153(1) was to be adhered to since the Assessing Officer sought to pass the original assessment order under section 143(3). The due date under section 153(1) was eighteen months from the end of the assessment year which was September 30, 2020. But in view of the extension given by virtue of the 2020 Act any due date of assessment proceedings falling between March 20, 2020 and December 31, 2020 was extended to March 31, 2021, and by Notifications Nos. 10 of 2021 dated February 27, 2021 ([2021] 432 ITR (St.) 14), 38 of 2021 dated April 27, 2021 ([2021] 434 ITR (St.) 11) and 74 of 2021 dated June 25, 2021 ([2021] 435 ITR (St.) 24), to April 30, 2021, June 30, 2021 and finally to September 30, 2021, respectively. The limitation period was as provided in section 153(1). Since the date of passing the draft assessment order under section 144C was itself September 28, 2021 and no final assessment order could be passed for the assessment year 2018-19 also the return of income filed by the assessee was to be accepted. This would however, not preclude the Department from taking any other steps in accordance with law. Relied on CIT v. Roca Bathroom Products P. Ltd (2022) 455 ITR 537 (Mad)(HC)  Roca Bathroom Products P. Ltd. v. DRP  (2021) 432 ITR 192 (Mad)(HC) (AY.2014-15, 2018-19)