https://www.taxtmi.com/caselaws?id=6356 For limitation under section 35(5) of the Indian Income-tax Act, 1922, the relevant final order is the one that finally completes the assessment or substitution directed on remand, not an earlier revisional order that merely requires fresh determination. The Commissioner's revisional order under section 33A(2) left the assessment open by directing the Income-tax Officer to re-examine the books and make a fresh estimate, so it was not the operative final order. The later order passed by the Income-tax Officer, which completed that exercise and substituted the estimate, triggered limitation. The rectification made within four years from that later order was therefore in time. en-us Fri, 08 Sep 1972 00:00:00 +0530 Thu, 04 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6356 For limitation under section 35(5) of the Indian Income-tax Act, 1922, the relevant final order is the one that finally completes the assessment or substitution directed on remand, not an earlier revisional order that merely requires fresh determination. The Commissioner's revisional order under section 33A(2) left the assessment open by directing the Income-tax Officer to re-examine the books and make a fresh estimate, so it was not the operative final order. The later order passed by the Income-tax Officer, which completed that exercise and substituted the estimate, triggered limitation. The rectification made within four years from that later order was therefore in time. Case-Laws Income Tax Fri, 08 Sep 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6356