https://www.taxtmi.com/caselaws?id=755182 ITAT Raipur held that Pr. CIT exceeded jurisdiction under Section 263 when revising a reassessment order for issues not forming the subject matter of reassessment. The AO had reopened the case under Section 147 for cash deposits but made no additions, thus losing jurisdiction for independent additions. Since the Pr. CIT's revision concerned share capital/premium and unsecured loans - distinct from the reassessment subject matter - the revision was invalid. The limitation period for Section 263 powers should commence from the original assessment date when reassessment issues differ from revision issues. Appeal decided in favor of assessee. en-us Thu, 04 Jul 2024 00:00:00 +0530 Sat, 06 Jul 2024 10:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755182 ITAT Raipur held that Pr. CIT exceeded jurisdiction under Section 263 when revising a reassessment order for issues not forming the subject matter of reassessment. The AO had reopened the case under Section 147 for cash deposits but made no additions, thus losing jurisdiction for independent additions. Since the Pr. CIT's revision concerned share capital/premium and unsecured loans - distinct from the reassessment subject matter - the revision was invalid. The limitation period for Section 263 powers should commence from the original assessment date when reassessment issues differ from revision issues. Appeal decided in favor of assessee. Case-Laws Income Tax Thu, 04 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755182