https://www.taxtmi.com/caselaws?id=468877 Where a reassessment is initiated on reasons unrelated to the issue later sought to be revised, the limitation for section 263 is computed from the original assessment order, not the reassessment order. The reassessment here did not address the section 14A read with Rule 8D disallowance that formed the basis of revision, so the earlier assessment remained the relevant starting point under section 263(2). As the revisionary action was initiated more than two years after that original order, it was barred by limitation and could not be sustained. en-us Mon, 10 Feb 2025 00:00:00 +0530 Sun, 24 May 2026 18:57:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468877 Where a reassessment is initiated on reasons unrelated to the issue later sought to be revised, the limitation for section 263 is computed from the original assessment order, not the reassessment order. The reassessment here did not address the section 14A read with Rule 8D disallowance that formed the basis of revision, so the earlier assessment remained the relevant starting point under section 263(2). As the revisionary action was initiated more than two years after that original order, it was barred by limitation and could not be sustained. Case-Laws Income Tax Mon, 10 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468877