In the result, appeal of the assessee is Allowed
reassessment proceeding\ninitiated U/Sec. 147 r.w.s.144 of the Act by the Ld.AO is without\njurisdiction and void ab initio as the impugned notice issued under\nsection 148 is time-barred as per the proviso to section 147 of the Act.\n2 The Ld. CIT(A) has erred in confirming that the assessment order\npassed by the Ld.AO U/Sec 147 rw.s.144