In the result, the stay application filed by the assessee is dismissed
Bench: Shri Kul Bharatshri Manish Borad
section 263(2), the notice issued on 30-4- 2009 was barred by limitation. 6.4 In Tata Power Company Ltd. Vs. PCIT (2021) 90 ITR TRIB (Trib) 554 (Mum), it was held that: 23 | P a g e "10. A perusal of the reasons recorded for reopening of assessment under s. 147 of the Act, as reproduced in the body