2013 (11) TMI 1059

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....or the assessment year 2005-06 on 30.10.2012 declaring the Net taxable income as nil and book profit computed under Section 115TB amounting to Rs. 17,66,14,319/-. The returns came to be processed under Section 143(1) of the Income Tax Act (hereinafter referred to as the Act) on 10.08.2006. Thereafter, a revised return of income came to be filed on 23.03.2007 declaring gross total income under the ....

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....on 16.06.2008 arriving at a gross total income of Rs. 27,28,51,217/- and accordingly the total income under the normal provisions of the Act, after set off and other deductions was arrived at as nil. 3. Thereafter, invoking suo motu jurisdiction under Section 263 of the Act, Commissioner of Income Tax, Cochin issued an order dated 18.03.2011 holding that order of the Assessing Officer giving ef....

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....Tribunal the present appeal is filed by the Revenue contending that initiation of proceedings under Section 263 of the Act dated 18.03.2001 is in respect of the orders of the CIT(Appeals) and therefore, question of limitation would not arise in the case on hand. 5. It is pertinent to note that the assessee went before the First Appellate authority against the initial assessment order not with r....