Explanation 2(c) to Section 147 is merely to explain the scope of re-assessment

Sanmina-SCI Technology India Private Ltd. Vs ACIT (Madras High Court)

Explanation 2(c) to Section 147 will not come to the aide of the relevance as, while the income chargeable has been made subject to excessive relief, the explanation cannot override the statutory prescription of limitation as set out in the proviso to Section 147. The purpose of the Explanation is merely to explain the scope of re-assessment as set out in the statutory provision and not to expand on or tinker with the limitation set out thereunder.

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