https://www.taxtmi.com/caselaws?id=431310 The appellant challenged the order passed under section 263 for the assessment year 2012-13, contending various grounds, including the limitation of the order. The primary contention was that the order passed by the Principal Commissioner of Income Tax (PCIT) under section 263 was barred by limitation as it went beyond the scope of the reopening of assessment under section 147. The dispute centered on whether the PCIT could expand the scope of reopening under section 147 in exercising revisionary jurisdiction under section 263. Ultimately, the court held that the PCIT's order was time-barred as it addressed issues beyond the scope of the original assessment or reopening, emphasizing the commencement of the limitation period from the date of the original assessment order. en-us Mon, 03 Oct 2022 00:00:00 +0530 Sat, 10 Dec 2022 11:13:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431310 The appellant challenged the order passed under section 263 for the assessment year 2012-13, contending various grounds, including the limitation of the order. The primary contention was that the order passed by the Principal Commissioner of Income Tax (PCIT) under section 263 was barred by limitation as it went beyond the scope of the reopening of assessment under section 147. The dispute centered on whether the PCIT could expand the scope of reopening under section 147 in exercising revisionary jurisdiction under section 263. Ultimately, the court held that the PCIT's order was time-barred as it addressed issues beyond the scope of the original assessment or reopening, emphasizing the commencement of the limitation period from the date of the original assessment order. Case-Laws Income Tax Mon, 03 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431310