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ITAT held that the revision order u/s 263 was barred by limitation, as the two-year period commenced from the date of intimation u/s 143(1). The tribunal distinguished between reassessment proceedings and revision proceedings, finding them unrelated in character. Consequently, the doctrine of merger was inapplicable, and the Commissioner's revision order was quashed. The tribunal set aside the order passed u/s 263, allowing the assessee's appeal on the ground of limitation, thereby providing relief to the taxpayer based on procedural technicalities.
ITAT held that the revision order u/s 263 was barred by limitation, as the two-year period commenced from the date of intimation u/s 143(1). The tribunal distinguished between reassessment proceedings and revision proceedings, finding them unrelated in character. Consequently, the doctrine of merger was inapplicable, and the Commissioner's revision order was quashed. The tribunal set aside the order passed u/s 263, allowing the assessee's appeal on the ground of limitation, thereby providing relief to the taxpayer based on procedural technicalities.
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