Limitation for Revision u/s 263 Starts from Original Assessment Date, Not Re-assessment Date.

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....Revision u/s 263 - Period of limitation - To be commenced from original assessment order or re-assessment order u/s 147 - In the case on hand, the jurisdiction under Section 263(1) of the Act was exercised with reference to an issue, which was covered in the original assessment order dated 28.12.2006 and it was not an issue, based on which, the reopening of assessment was made under Section 143 of the Act. For all purposes, the period prescribed under Sub-Section (2) of Section 263 of the Act should commence from 31.3.2007 and the two years' period would come to an end on 31.3.2009. - HC....