In the result, both the appeals are dismissed
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
147 reads as under: "Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment for such