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Submitted for the consideration of the Hon'ble Tribunal."

7. I have given my thoughtful consideration to rival contentions. Mr. Damle vehemently contends during the course of hearing that all four re-assessments framed in the impugned as many as assessment years are time barred. I deem it appropriate at this stage to recapitulate the relevant facts once again. The Assessing Officer admittedly set sec. 148 re-opening mechanism in motion in identical four notices issued on 16.02.2016 which stood served on the taxpayer on 19.02.2016 followed by the impugned re-assessments framed on 08.11.2017. Section 153 of the Act prescribes time limit for completion of assessment, re-assessment & re-computation. Sub-section 2 thereof makes it clear that no order of assessment, re-assessment or re-computation shall be made u/s 147 after expiry of nine months from the end of the financial year in which sec. 148 notice stood served. There can hardly be any dispute about nine months from the end of the financial year of such section 148 notice service dated 19.02.2016; last upto 31.12.2016. The Revenue's submission extracted hereinabove are fair enough to this effect. I therefore observe that last date of framing of re- assessments in all these assessment years was 31.12.2016.