https://www.taxtmi.com/caselaws?id=299650 The Tribunal found that the order under section 263 of the Income Tax Act was barred by limitation as it was passed well beyond the prescribed period from the original assessment order. The error in applying the Gross Profit rate on the turnover was deemed to be in the original assessment order under section 143(3), not in the subsequent order under section 147. Relying on the doctrine of merger and relevant case law, the Tribunal held that the order under section 263 was invalid due to being time-barred. Consequently, the Tribunal vacated the order under section 263, ruling in favor of the appellant. en-us Wed, 30 Sep 2015 00:00:00 +0530 Fri, 24 Dec 2021 10:35:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=299650 The Tribunal found that the order under section 263 of the Income Tax Act was barred by limitation as it was passed well beyond the prescribed period from the original assessment order. The error in applying the Gross Profit rate on the turnover was deemed to be in the original assessment order under section 143(3), not in the subsequent order under section 147. Relying on the doctrine of merger and relevant case law, the Tribunal held that the order under section 263 was invalid due to being time-barred. Consequently, the Tribunal vacated the order under section 263, ruling in favor of the appellant. Case-Laws Income Tax Wed, 30 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=299650