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The HC held that the two-year limitation period under Section 263(2) must be computed from the date of the original assessment order under Section 143(3), not from the reassessment order date. Since the reassessment pertained solely to capital gains and did not affect deductions under Section 43B considered in the original order, the original assessment order was not merged with the reassessment. Consequently, the revision order under Section 263 was barred by limitation as it related to an issue covered by the original assessment. The Tribunal's decision to set aside the revision order as time barred was upheld.
The HC held that the two-year limitation period under Section 263(2) must be computed from the date of the original assessment order under Section 143(3), not from the reassessment order date. Since the reassessment pertained solely to capital gains and did not affect deductions under Section 43B considered in the original order, the original assessment order was not merged with the reassessment. Consequently, the revision order under Section 263 was barred by limitation as it related to an issue covered by the original assessment. The Tribunal's decision to set aside the revision order as time barred was upheld.
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