Revisional Order on Second Issue Barred by Limitation u/s 263(2); Principal Commissioner's Action Unsustainable.

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....Revision u/s 263 - Period of limitation - the limitation prescribed under section 263(2) would run from original assessment in respect of issue alien to reasons recorded. Thus, when seen qua the original assessment, the revisional order on the second issue is clearly barred by limitation. The action of the PCIT on the second issue thus cannot be countenanced. - AT....