Revision limitation runs from the original assessment when proposed issues fall outside the reassessment's subject matter.

Revision on matters unrelated to a reassessment must be initiated within the limitation period calculated from the original assessment order. Where reassessment was confined to alleged bogus purchases, revision concerning gifts to doctors, expenditure relating to exempt income, and CSR deduction could not rely on the reassessment order to extend limitation. Although audit objections were available during reassessment, those issues were not brought within its scope. The notes state that the revisionary proceedings were time-barred and the section 263 order was quashed.

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Issues: Whether revision under section 263 on issues unrelated to the subject matter of reassessment was barred by limitation.

Analysis: The reassessment was initiated solely for alleged bogus purchases, whereas the proposed revision concerned gifts to doctors, disallowance of expenditure relating to exempt income, and deduction for CSR expenditure. Those matters arose from and had been examined in the original assessment. Where the subject matter of revision is distinct from the subject matter of reassessment, the limitation for revision runs from the original assessment order; it cannot be extended by treating the reassessment order as the relevant order. The audit objections were available during reassessment, but the reassessment was not enlarged to cover those matters.

Conclusion: The revisionary proceedings were time-barred and the order under section 263 was quashed, in favour of the assessee.

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