Revision limitation for issues outside reassessment runs from the original assessment, rendering a belated revision without jurisdiction.

Revision under section 263 on an issue outside the scope of reassessment must be initiated within the limitation period computed from the original assessment order, not the reassessment order. Where reassessment was confined to verifying alleged fictitious losses from equity or derivative trading, a revision concerning discrepancy in professional or consultancy fees concerned a separate issue. The notes state that the revision was initiated beyond the prescribed period and was therefore time-barred and without jurisdiction.

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Issues: Whether revision under section 263 in respect of an issue not forming part of reassessment was barred by limitation.

Analysis: Reassessment had been initiated only to verify alleged fictitious losses in equity/derivative trading, whereas the revision addressed a discrepancy in professional or consultancy fees. For an issue outside the subject matter of reassessment, the limitation for revision runs from the original assessment order and not from the reassessment order. The revision was consequently initiated beyond the prescribed period.

Conclusion: The revision order was time-barred and without jurisdiction; the issue is decided in favour of the assessee.

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