https://www.taxtmi.com/caselaws?id=469198 A revisionary order under section 263 must be preceded by a show-cause notice and a real opportunity of hearing; otherwise it suffers from jurisdictional infirmity and cannot be sustained. The text further states that where the statutory limitation under section 263(2) has already expired, the defect cannot be cured by remand for fresh consideration, because that would effectively revive or extend a limitation period the statute does not permit to be extended. On that reasoning, the revisional order was quashed and the assessee succeeded. en-us Thu, 25 Sep 2025 00:00:00 +0530 Tue, 09 Jun 2026 20:44:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469198 A revisionary order under section 263 must be preceded by a show-cause notice and a real opportunity of hearing; otherwise it suffers from jurisdictional infirmity and cannot be sustained. The text further states that where the statutory limitation under section 263(2) has already expired, the defect cannot be cured by remand for fresh consideration, because that would effectively revive or extend a limitation period the statute does not permit to be extended. On that reasoning, the revisional order was quashed and the assessee succeeded. Case-Laws Income Tax Thu, 25 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469198