https://www.taxtmi.com/caselaws?id=801412 Revision of an issue outside the scope of reassessment is time-barred where the limitation period for revision runs from the original assessment order. Reassessment initiated for specified financial transactions did not encompass the debenture redemption reserve, which had already been addressed in the original assessment. Section 147, including Explanation 3, permits assessment of another escaped-income issue that comes to notice during reassessment, but no material established that the reserve issue arose in those proceedings. The original assessment therefore remained operative for that issue, and revision concerning the reserve was barred by limitation. en-us Wed, 14 Oct 2026 00:00:00 +0530 Wed, 21 Oct 2026 08:37:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801412 Revision of an issue outside the scope of reassessment is time-barred where the limitation period for revision runs from the original assessment order. Reassessment initiated for specified financial transactions did not encompass the debenture redemption reserve, which had already been addressed in the original assessment. Section 147, including Explanation 3, permits assessment of another escaped-income issue that comes to notice during reassessment, but no material established that the reserve issue arose in those proceedings. The original assessment therefore remained operative for that issue, and revision concerning the reserve was barred by limitation. Case-Laws Income Tax Wed, 14 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801412