Assessee-firm filed return of income for assessment year 2014-15. During survey proceedings, undisclosed income was found, and the same was added to the income of assessee. Commissioner (Appeals) partly allowed the appeal and held that the addition made by Assessing Officer was to be made in the respective assessment years 2011-12 to 2014-15 inasmuch as project based on which gross profits were estimated was completed during the duration of the assessment years 2011-12 to 2014-15. In compliance with the directions of the Commissioner (Appeals), the Assessing Officer issued notices under section 148 for reopening the assessment for the relevant years. Assessee raised objections on the ground that, as per section 150(2), which restricts power under section 150(1), to give direction to reopen assessment, the period of limitation prescribed under section 149(1) had expired. However, Assessing Officer disposed of objections on the ground that notices were issued in compliance with the directions issued by the Commissioner (Appeals). On writ, the Court held that, as per section 150(1), notice under section 148 can be issued at any time to give effect to a direction passed by the Commissioner (Appeals).However, provisions of section 150(1) are subject to section 150(2), which provides that section 150(1) shall not be applied in a case where assessment, in respect of which direction was passed by the Commissioner (Appeals), could not have been reopened at the time of passing such appellate order. Since Commissioner (Appeals) had issued direction after the expiry of four and six years, respectively, for assessment years 2011-12 and 2012-13, no assessment or reassessment could be made as the time period prescribed under section 149 had already expired, and thus, the Assessing Officer could not have reopened the assessment in compliance with said direction. (AY. 2011-12, 2012-13)