Judgment :- 1. The following question has been. at the instance of the revenue. referred to us by the Income-tax Appellate Tribunal. Cochin Bench: "Whether on the facts and in the circumstances of the case. the additions of Rs. 13.500/-. Rs. 25.000/-. and Rs. 22.500/-. as directed by the Inspecting Assistant Commissioner u/s.144A are barred by limitation?" In respect of the assessment year 1974-75. the Income-tax Officer in exercise of his power under S.144-B of the Income-tax Act. 1961 proposed to make a variation in the income returned by the assessee for the previous year in regard to certain items. The draft order was forwarded to the assessee calling for his objections. In regard to four of the items on which variation was proposed to be made. the assessee's submissions were accepted and the amounts were computed accordingly. In regard to the other items. the assessee raised objections. The Officer accordingly forwarded the draft order and the objections of the assessee to the Inspecting Assistant Commissioner. The Inspecting Assistant Commissioner after considering the objections and after hearing the assessee's representative recomputed the amounts in regard to the four items on which the Income-tax Officer had originally accepted the submissions made by the assessee. It is stated in the order of the Inspecting Assistant Commissioner that the four items in question were recomputed in concurrence with the assessee's representative and it was on the basis of such concurrence that the additions were made. Three of the additions so made by the Inspecting Assistant Commissioner were the subject matter of challenge by the assessee in his appeal before the Appellate Assistant Commissioner. but without success. The Tribunal on further appeal by the assessee. however. accepted the assessee's contentions. and held that the re-computation of the items in question was made by the Inspecting Assistant Commissioner in the purported exercise of his power under S.144A after the normal period of assessment prescribed under S.153 (1) (a) (iii) had expired. and was. therefore. time-barred. The Tribunal accordingly set aside the additions made on the basis of the re-computation in regard to the three items which are now the subject matter of the question re erred to us. 2. Counsel for the revenue contends that in a case where reference has been validly made under S.144-B before assessment is completed. the period of limitation. prescribed under S.153(1)(a)(iii). 2. Counsel for the revenue contends that in a case where reference has been validly made under S.144-B before assessment is completed. the period of limitation. prescribed under S.153(1)(a)(iii). for completion of the assessment is extended by reason of the exclusion. in computing that period. of the time specified under Explanation I(iv) to S.153. During such extended period. it is open to the Inspecting Assistant Commissioner to exercise his power under S.144-A and give such directions as be deems fit to the Income-tax Officer in regard to any matter connected with the assessment. even when such a matter does not figure in the draft order and the normal period prescribed by S.153(1) has expired. Counsel submits that by recourse to S.144-A. and in exercise of the suo mote power conferred by that Section. it is open to the Inspecting Assistant Commissioner to give any direction which be deems necessary to the Income-tax Officer. and the Officer is bound to carry out such a direction. Counsel further submits that the re-computation of the amounts as regards the four items on which the assessee raised no objections was an exercise of the suo mote power under S.144-A(1). and such exercise of power was not barred by limitation by reason of the extension of time in terms of Explanation l(iv) to S.153 consequent on the reference made under S.144-B. 3. Counsel for the assessee Shri. Sudheer Gopi. however. submits that the period of limitation prescribed under S.153(1)(a)(iii) is extended in terms of Explanation I only to the extent that the Income-tax Officer is authorised to make a reference under S.144-B. Such extended period cannot be availed of for any other purpose. The suo mote power under S.144-A can be exercised only within the normal period of two years prescribed by S.153(1)(a) (iii). Counsel further submits that. in any view. in regard to the four items on which the amounts were recomputed by the Inspecting Assistant Commissioner. there was no reference as the amounts in regard to these items had been varied by the Income-tax Officer in accordance with the submission of the assessee. In regard to such items. the Inspecting Assistant Commissioner. counsel says. was not entitled to make a re-computation. even if it was done with the concurrence of the assessee. 4. there was no reference as the amounts in regard to these items had been varied by the Income-tax Officer in accordance with the submission of the assessee. In regard to such items. the Inspecting Assistant Commissioner. counsel says. was not entitled to make a re-computation. even if it was done with the concurrence of the assessee. 4. The normal period of two years prescribed by S.153(1) (a) (iii) for completion of assessment is automatically extended for a further period. as provided under Explanation I (iv) to that Section. as soon as a draft order under S.144-B (1) is forwarded to the assessee by the Income-tax Officer. This is because Explanation I to S.153 provides for exclusion. in the specified cases. of the specified length of time in the computation of the relevant period of limitation. When the time is so extended. these being only one assessment. all questions relating to that assessment are open to be dealt with during the extended period. Since the Inspecting Assistant Commissioner has power under S.144-A to issue directions either suo motu or on a reference or on an application by an assessee. he may suo motu issue directions whenever he finds it necessary to do so in regard to any matter relating to the assessment. If directions are issued by him on matters not arising from the reference. as in the present case. such directions emanate from his suo motu power under S.144-A. The time for completing the assessment having been statutorily extended by reason of the reference for the additional period prescribed under Explanation I (iv) to S.153. the re-computation of the amounts by the Inspecting Assistant Commissioner. whether or not with the concurrence of the assessee. on items on which the assessee had not raised any objection on receipt of the draft order. was a perfectly valid exercise of power in terms of S.144-A(1). 5. Accordingly we answer the question in the negative. that is. in favour of the revenue and against the assessee. 6. We make it clear that we express no view as regards the quantum of the additions made on the three items in question. for that was not a matter which. although raised. was dealt with by the Tribunal. 7. We direct the parties to bear their respective costs in this Tax Referred Case. 6. We make it clear that we express no view as regards the quantum of the additions made on the three items in question. for that was not a matter which. although raised. was dealt with by the Tribunal. 7. We direct the parties to bear their respective costs in this Tax Referred Case. A copy of this judgment under the seal of the High Court and the signature of the Registrar shall be forwarded to the Income-tax Appellate Tribunal. Cochin Bench.