https://www.taxtmi.com/caselaws?id=210850 HC upheld the Tribunal's decision that the Commissioner's order u/s 263 was barred by limitation u/s 263(2). The original assessment u/s 143(3) had allowed deductions u/s 36(1)(vii), 36(1)(viia) and on foreign exchange differences. These issues were never the subject of the subsequent reassessment orders u/s 147, hence the doctrine of merger did not apply, and the original assessment order continued to subsist on those aspects. Consequently, the limitation period for exercising revisional jurisdiction ran from the date of the original assessment, not the reassessment orders. Explanation 3 to s.147 did not override the specific time-bar in s.263(2). The revenue's appeal was dismissed. en-us Wed, 08 Feb 2012 00:00:00 +0530 Wed, 03 Dec 2025 15:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210850 HC upheld the Tribunal's decision that the Commissioner's order u/s 263 was barred by limitation u/s 263(2). The original assessment u/s 143(3) had allowed deductions u/s 36(1)(vii), 36(1)(viia) and on foreign exchange differences. These issues were never the subject of the subsequent reassessment orders u/s 147, hence the doctrine of merger did not apply, and the original assessment order continued to subsist on those aspects. Consequently, the limitation period for exercising revisional jurisdiction ran from the date of the original assessment, not the reassessment orders. Explanation 3 to s.147 did not override the specific time-bar in s.263(2). The revenue's appeal was dismissed. Case-Laws Income Tax Wed, 08 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210850