64.   Limitation for assessment.-

(1)   No assessment under section 59A, section 62 or section 63 shall be made after the expiration of two years from the end of the assessment year in which the total income was first assessable.

(2)   Notwithstanding anything contained in sub-section (1), where a return of total income has been filed after the end of the financial year in which the last date of filing of such return specified in section 55 falls, no assessment under section 59A, section 62 or section 63 shall be made after the expiration of two years from the end of the financial year in which the said return is filed.

(3)   Notwithstanding anything contained in sub-section (1), where, for any income year, an assessee has failed to furnish the return of total income, no assessment under section 62 or section 63 shall be made after the expiration of two years from the end of the financial year in which notice under section 56, sub-section (3) of section 72 or sub-section (3) of section 81, as the case may be, was served.