2023 (6) TMI 1047

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... Ravikumar For the Appellant(s) : Mr. N Venkatraman, A.S.G. (Not Present), Mr. Arijit Prasad, Sr. Adv., Mr. V Chandrashekhara Bharathi, Adv., Mr. Raj Bahadur Yadav, AOR, Mr. Rupesh Kumar, Adv., Mrs. Sunita Sharma, Adv., Mr. A. K Kaul, Adv., Mr. Adit Khorana, Adv., Ms. Aakansha Kaul, Adv. And Ms. Sunita Sharma, Adv. ORDER Feeling aggrieved and dissatisfied with the impugned judgment and o....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... it is required to be noted and it is not in dispute that, as such, the Commissioner exercised powers under Section 263 of the Act with respect to the issues which were not covered in the re-assessment proceedings. Therefore, the issues before the Commissioner while exercising the powers under Section 263 of the Act relate back to the original Assessment Order and, therefore, the limitation would ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....assessment, the limitation would start from the date of Re-assessment Order. However, if the subject matter of the re-assessment is distinct and different, in that case the relevant date for the purpose of determination of period of limitation for exercising powers under Section 263 of the Act would be the date of the original Assessment Order. In view of the above and for the reasons stated he....