Section 263 limitation runs from the original assessment date; reassessment did not revive the Revenue's revisional power.

Limitation for revision under section 263 of the Income-tax Act was computed from the date of the original assessment under section 143(3), and the later reassessment under section 147 did not shift that starting point on the facts. The Tribunal's limitation finding was treated as a mixed question of law and fact, and it was not shown to be perverse or vitiated by any apparent error of law. Reliance on Explanation 3 to section 147 did not assist the Revenue. The Revenue's challenge therefore failed, and the revisional order was not interfered with.

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Issues: Whether the Revenue's appeal raised any substantial question of law on the issue of limitation under section 263 of the Income-tax Act, 1961, where the reassessment order had been passed after reopening under section 147.

Analysis: The original assessment was completed under section 143(3) of the Income-tax Act, 1961, and the limitation for exercise of revisional power under section 263(2) was held to run from the date of that original assessment. The subsequent reassessment did not alter the relevant starting point on the facts of the case. The finding of the Tribunal on limitation was treated as a finding on a mixed question of law and fact and was not shown to be perverse or vitiated by any apparent error of law. In those circumstances, reliance on Explanation 3 to section 147 did not advance the Revenue's case.

Conclusion: No substantial question of law arose. The limitation finding in favour of the assessee was upheld.

Final Conclusion: The Revenue's challenge failed, and the revisional order under section 263 was not interfered with.

Ratio Decidendi: For purposes of section 263(2) of the Income-tax Act, 1961, limitation is computed from the date of the original assessment order, and a finding on that issue will not be disturbed unless it is perverse or contrary to law.

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