Disposing the  appeal  the Court held that  ,the Assessing Officer shall complete the assessment for Assessment Year 2013-14 pursuant to the notice for reassessment which has been issued on 23 March 2018, in accordance with law. The issue as to whether the notice under section 148 for reopening the assessment for Assessment Year 2013-14 is valid is kept open to be urged in appropriate proceedings after the assessment order is passed. Upon the passing of the order of assessment for Assessment Year 2013-14 and in order to enable the assessee to pursue its remedies before the Commissioner of Income Tax (Appeals) there shall be an interim protection in terms of the order that was passed by the Division Bench of the Bombay High Court in Saibaba Sansthan Trust.  Both the appeals for the Assessment Years 2013-14 and 2015-16 shall be heard together by the Commissioner of Income Tax (Appeals). The appellant shall be at liberty to pursue its remedies in accordance with law. (AY. 2013 -14 )