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Provided that no notice under this sub-section shall be served on the assessee after the expiry of six months from the end of the financial year in which the return is furnished."

I.T.A. No.222 & 223/Lkw/2017 Assessment Year:2008-09 & 2009-10 The examination of these provisions regarding completion of assessment indicate that Assessing Officer may require the assessee to produce or cause to be produced before him any evidence on which the assessee may have relied in support of the return. The provision further clarifies that no notice under this sub section shall be served upon the assessee after the expiry of six months from the end of the financial year in which the return was furnished. In the present case the original return was filed on 14/08/2008 and Assessing Officer had in his disposal a period upto 30th September, 2009 for the issue of notice u/s 143(2) of the Act and therefore, unless that period expires, the assessment cannot be said to have been completed as the Assessing Officer is empowered to issue notice within a period of six months from the end of financial year in which the return of income is filed and therefore, upto 30/09/2009 the assessment was pending. Now the time limit provided by the provisions of Act for filing revised return of income is one year from the end of assessment year and therefore, the period for filing of return was available upto 31/03/2010. The other condition that revised return can be filed before the completion of assessment and in this case the assessment was pending upto 30/09/2009. The earlier of the two dates is 30/09/2009 and therefore, any revised return filed before 30/09/2009 is a valid revised return. The assessee on 12/11/2008 itself filed revised return of income. The said filing of revised return fulfills both the conditions i.e. the revised return has been filed before the expiry of one year from the end of relevant assessment year and has also been filed before the completion of assessment. Such revised return, which was validly filed, replaces the original return of income and for assessment purposes the original return was to be ignored and only revised return was to be considered. This has been held in a number of cases. Hon'ble Punjab & Haryana High Court in the case of Beco Engineering Co. Ltd. vs. CIT [1984] 148 ITR 478 has held as under: