2022 (6) TMI 1358

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....the Respondent : Mr. R. Vijayaraghavan (In all cases) for Subbaraya Aiyar. COMMON JUDGMENT Order of the court was made by MOHAMMED SHAFFIQ, J. The short question that arises for consideration is, whether the limitation for the purpose of invoking jurisdiction under Section 263 of the Income Tax Act, 1961 (hereinafter referred to as "the Act") in respect of items/ income assessed originally and ....

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....ad with 147 of the Act on 26.12.2006, 31.12.2007 and 31.12.2007 respectively. 3. Thereafter, the Commissioner of Income Tax issued show cause notices under Section 263 of the Act and passed orders by setting aside the 2 nd assessment orders for the assessment years 1999-2000, 2001-2002 and 2002-2003 on 27.03.2009, 27.03.2009 and 27.03.2009 respectively. 4. Challenging the aforesaid orders passed....

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.... Court in the case of CIT v. Alagendran Finance Ltd. [(2007) 293 ITR 1 (SC)] wherein it was held as under: "25....We therefore, are clearly of the opinion that keeping in view of the facts and circumstances of this case and, in particular, having regard to the fact that the Commissioner of Income-tax exercising his revisional jurisdiction reopened the order of assessment only in relation to leas....