In the result, this appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Aman Enterprises, D.C.I.T., 22, Park Street, Near Doranda College, Circle-1, Vs. Ranchi-834002 (Jharkhand) Ranchi. Pan No. Aaifa 9921 A Appellant/ Assessee Respondent/ Revenue

disallowances of expenses was made. 2. That subsequently proceeding U/s 148 was initiated vide notice dated 18/08/2017 i.e. beyond 4 years and an order U/s 147 rws 144 was passed on 26/11/2018. 3. That the legal issue which we intend to challenge is that this impugned proceedings has been initiated beyond a period of 4 years wherein an original assessment