https://www.taxtmi.com/caselaws?id=248977 Limitation for revision under section 263 of the Income-tax Act was computed from the date of the original assessment under section 143(3), and the later reassessment under section 147 did not shift that starting point on the facts. The Tribunal's limitation finding was treated as a mixed question of law and fact, and it was not shown to be perverse or vitiated by any apparent error of law. Reliance on Explanation 3 to section 147 did not assist the Revenue. The Revenue's challenge therefore failed, and the revisional order was not interfered with. en-us Wed, 11 Jun 2014 00:00:00 +0530 Tue, 01 Jul 2014 08:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248977 Limitation for revision under section 263 of the Income-tax Act was computed from the date of the original assessment under section 143(3), and the later reassessment under section 147 did not shift that starting point on the facts. The Tribunal's limitation finding was treated as a mixed question of law and fact, and it was not shown to be perverse or vitiated by any apparent error of law. Reliance on Explanation 3 to section 147 did not assist the Revenue. The Revenue's challenge therefore failed, and the revisional order was not interfered with. Case-Laws Income Tax Wed, 11 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248977