Limitalion on

1. (1) No assessment or re-assessment shall be made by the Commissioner after the expiry of four years from- and re- ~ssessmeot.
   • (a) the date on which the person furnished a return under section 26 or sub-section
     • (I) of section28; or
2. (6) the date on which the Commissioner made an assessment of tax under settion 32, whichever is the earlier: Provided that where the Commissioner has reason to believe that tax was not paid by reason of concealment, omission or failure to disclose material particulars on the part of the person, the assessment or re-assessment may be made by the Commissioner within six years from the dates specified in clause
   • (a) or clause (b), as the case may be.
3. (2) Notwithstanding anything contained in sub-section (I), the Commissioner may make

an assessment of tax within one year from the date of any decision of the Appellate

Tribunal or court where the assessment is required to be made in consequence of, or to give effect to, the decision ofthe Appellate Tribunal or court which requires the re-assessment of the person.